In general, Community Living Alternatives supports and endorses the comments of vaACCSES with emphasis placed on the following points:

• Such documentation shall be written on the date of service delivery.  Strike or change to as soon as practicable but no longer than one week after the service.  This is in keeping with the definition of Progress Note from this chapter.
• Support changing the 10-day requirement to a 15-day requirement for service providers to submit quarterly reports.
• C5. The orientation is a knowledge-based assessment, while the competencies are both knowledge and action based. On many of the competencies, you are required to assess action and knowledge. Where I have found the deficiencies to be is in the action part of the competencies. Therefore, retaking the orientation test is not a valid way of training for action. Having statewide readily available online training tools for the competencies from department would be helpful. 
• A.1- Delete “to 72” and add “or older” after “years of age.”  If the SIS is only validated to age 72 then language should be added to automatically assign all individuals age 72 or older to Level 5, Tier 4. Level 5 is the highest level denoting significant need in general but not specifying it to medical or behavioral.  Tier 4 is mid-range denoting significant need, which is appropriate for an aging population.  However, there should be a statement that these individuals shall not be excluded from consideration of an individualize rate because of medical or behavioral needs.
• Add a new E.- “An automatic, independent review of the SIS administration process and results when an individual’s SIS Score changes despite a lack of change in their health or other circumstances, upon request.”

Thank you for the opportunity to respond to these proposed regulations.

Susan Keenan

Community Living Alternatives