In review of the updated competency checklist for DBHDS Licensed Providers that has been sent out for public comment, I take a minute to pause and really think about the true intention of this checklist. In review of the independent reviewer’s most recent report and prior reports, the following within section V.H.1 of the report is noted; “The Commonwealth shall have a statewide core competency-based training curriculum for all staff who provide services under this Agreement. The training shall include person-centered practices, community integration and self-determination awareness, and required elements of service training.”
I know that the increased competency requirements that Providers have witnessed throughout the state is a direct result of the outlined requirement that the state must uphold; however the way in which this can be tackled is not felt to be through the completion of checklists.
Additionally, the new guidance material indicates that the 8 page document would require additional processing in the amount of two or more times through each DSPs personnel file, as the Competency 3 section is required prior to service delivery in the absence of a proficient staff person, which would indicate that this checklist must first have section 3 completed and verified and sections 1 and 2 completed within 180 days with proficiency noted during that time frame as well. This appears to be a focus away from service delivery and more on the completion of a checklist, that may or may not accurately outline the skills of the noted staff, due to the implications that are present if this form is not present or not completed as it is should be.
We as Provider Agencies are open to meeting all requirements; however in working directly with the current system, it appears to be a consensus that changes are needed, as the way in which additional checklists and requirements continue the end result is not aligning with the outlined goal.