With regards to the change:  "Competency 3 and all related skills must be confirmed competent prior to providing support in the absence of paid staff who has demonstrated proficiency with this competency." - page 7

1.  3.2 - Provides medication as prescribed - DSPs at SSVA do not receive medication training prior to working alone.  SSVA offers medication training quarterly and enrolls employees in this training based on hire date and recommendation from supervisors (slots are limited).  Because of the high cost of medication certification and high turnover rates in the field, it is not reasonable to expect employers to put DSPs through medication training before working alone.  SSVA coordinates med certified staff to cover medication needs of individuals supported in instances where staff who are not yet med certified are scheduled.

2.  Tracking completion of lengthy competency  checklists is cumbersome enough with the requirement of 180 days and every year thereafter for every employee and sponsor.  To add an extra tracking date of before working alone and then every year after adds another level to already overburdened administration system.

3.  All DSPs must be certified in CPR / First Aid and Infection Control and DSPO prior to working alone.  The majority of the items covered in part 3 of the competency checklist are covered in these trainings.