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I wanted offer comment to the proposed regulation indicating that the quarterly reviews need to be in the individual’s record no later than 15 calendar days from the date the review was due to be completed.  This is a concern for Case Managers/Support Coordinators as they need to receive and review the providers quarterly reviews  incorporating  the information in their review.

There are occasions in which the provider is late or does not provide quarterly documentation at all, even with numerous follow up by the CM/SC.  This regulation will prevent the CM/SC an opportunity to review the provider quarterlies and synthesize the information as needed.  It would also create a potential citation for not meeting a regulation when it is not within their control.

Can the regulation be edited to offer a period of time for the CM/SC to review provider quarterlies and then complete the Case Management quarterly?