The following outlines our input in this section:

• Within (A) of this section, there is significant concern about the proposed requirement that the format of progress notes be consistent throughout all the services a provider offers. We propose the requirement for a consistent format in progress notes be by service. This will enable providers to utilize the most appropriate progress note format depending on the type of service.
• Within (B) of this section, we propose that the minimum progress notes requirements be amended as follows:
  • Remove the current (1) as this is clearly stated in (A).
  • In the current (3), remove, “including care provided and events relevant to diagnosis and treatment or care of the individual,” recognizing that the language prior to that, “record events of the individual’s interaction with the clinical staff writing the progress note,” is sufficient.
  • Remove current (4) (“have a narrative component”) which doesn’t seem necessary.
  • Amend the current (5) to read, “Note the ISP objectives being addressed.”
  • Add to the requirements a new (4) that reads, “Outline the plan for the next session.”