Thank-you for the opportunity to provide comments.

DSP Competencies Checklist:

Comment: Page 5 of 8 for DMAS #P241a - Competency 3. - Reconsider having two supervisory signatures. Smaller programs and some group homes only have one supervisory level assessing competencies and providing the training needed to reach proficiency.  In some cases, there may not be a second person available to observe and assess proficiency.  In Day Programs this was not previously required and will add administrative burden. If we trust supervisory personnel to assess proficiency in other areas, this should be sufficient in the area of competencies.

Comment: Consider revising the competencies for Medical, Autism, and Behavior (forms DMAS #P201, DMAS #P244a and DMAS #P240a) - to streamline these competencies.

Comment: There is a concern about the required training for the Medical, Autism and Behavior competencies. There are not many certified training programs available and those that are available are costly. Most providers do not have access to the list of professionals who must sign off on the in-house developed training as indicated.