12VAC 30-122-120 d states progress notes must be completed on the day services are provided. However 12VAC 30-122-20 Definitions "Progress Notes" iii states: is written and signed and dated as soon as practicable but no longer than one week after the referenced service. I believe these sections are in direct conflict. 

The added requirement to finalize progress notes on the day services were provided has the affect of interfering with the primary responsibility of fully supporting the person receiving Medicaid waiver services. This proposed change adds stress to providers

We are a sponsored placement provider. We are a couple that work tirelessly to provide quality services. We do not have additional staff to provide services while someone else sits down to write progress notes, and expend the thought required to adequately capture the day's activities.

We jot down simple notes throughout the day, and in a typical day, we complete the progress notes form at the end of the day. However, there are days when we need to postpone completing the form until the next day.