We sincerely appreciate the efforts of the Office of Licensing to improve coordination with the requirements of the Department of Medical Assistance Services on the topic of quarterly progress reviews.  As stated, the proposed change is unclear regarding whether or not the progress review itself may be completed within 15 days of the end of the quarter, or only the documentation of said review.  We request language clarification such that the actual review may be completed within a specified window after the end of the quarter.  This is a more natural process, as the documentation of such a review is typically completed concurrent with the actual review of affiliated information (e.g. progress notes, summaries provided by other providers).  In addition, we request an alteration of the approach, using previously articulated DMAS requirements for providers of intellectual disability services, wherein a reasonable grace period (e.g. 15 days) is allotted to providers of services other than case management, while a more extended grace period is allotted to case managers (e.g. 30 days). This will allow case managers the opportunity to review and synthesize information from other providers into their review and their updates to the ISP, a key requirement of this service and an expectation for support coordinators assisting individuals with developmental disabilities.