1) There are many skills under Competency 3 that could be N/A for some DSPs. Does the use of N/A apply to Competency 3 (specifically 3.2, 3.3, and 3.5) if a skill is N/A for a particular DSP in a Day Support program? There is a statement that “competency 3 and all related skills must be confirmed as competent prior to providing support in the absence of paid support who…..”

 *Suggestion: add a statement that the use of N/A is permitted in all sections of the checklist or in the note under competency 3, state that the use of N/A is permitted.

3.2 – the observation (indicators) – this area needs clarification because if the DSP is not medication certified, then it would be marked N/A. However, the DSP should be able to describe the process for reporting unusual health events according to agency procedures.

2) 2.3 – it needs to be clear that DSPs can document alongside another DSP deemed proficient, and providers can bill for services even if the DSP is not proficient yet. 

There is a documentation issue and conflict – It’s implied that Providers cannot bill for services until the DSP providing services is found proficient and until this form has been completed and signed, yet documentation is needed to bill. In order to determine if the new DSP is proficient, they must demonstrate they are proficient with documenting services provided with the required elements. This would be difficult to determine unless the DSP is documenting actual services provided.  This needs to be addressed.

Thank you