Thank you for giving me the opportunity to make comments on the draft Center-Based Chapter. You will find my comments and recommendations below.

Throughout the entire document, I would like to recommend removing Substance Abuse and replacing it with Substance Use Disorder. I also recommend removing Mental Retardation with Developmental Disability/Intellectual Disability.

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I would like to recommend adding a definition for Supported Decision Making to this section

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Recommend changing Medical Symptoms to Medical Conditions.

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Recommend changing Medical Symptoms to Medical Conditions.

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D. Add “and available” after if applicable.

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A.1 & 2 Recommend changing 24 hours after admission to 1 business day.

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E. While I agree that employees should be knowledgeable about the contents of ISPs for individuals served, establishing expectations to train and test all employees involved with service delivery is an unrealistic expectation that will significantly detract from service delivery. Observations of competency and knowledge about providing services is part of the supervisory and evaluation process. Moving forward with this is likely to result in providers making fewer updates to ISPs, to avoid retraining and testing employees. There is no practical way to document this knowledge and competency without documentation of confidential information about individuals served, which should not be part of a Personnel File. This expectation places an undue burden on Human Resources who would have to maintain the documentation, as well as supervisors who would have to develop ways to test and train employees while maintaining their other responsibilities.

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C. Asking for clarification if quarterlies are required for this service.

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B.5 This would be easier to identify for some services, such as outpatient, but not for a day program. This is an impractical expectation for daily service documentation..

B.6 Replace clinal staff with qualified staff. 

C Add informational notes along with communication logs and supervision notes.

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A.3 & 4 Recommend to remove will provide as we cannot provide medical or dental services as we are not medical professionals.

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B.2.b Remove as this pertains to residential services, not center-based services.

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E Please make consistent throughout DBHDS regulations. The temperature range for center-based services is different than the temperature range for residential.

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G This is an impractical expectation for programs due to the administrative burden. This is not required for any other DBHDS licensed service, request this requirement to be removed.