We are seeking guidance regarding Section (A) of this provision.  The provision calls for “written policies and procedures for a quality improvement program sufficient to identify, monitor, and evaluate clinical and service quality and effectiveness.”  We are seeking clarification as to the standard of sufficiency being utilized by the Department.  In order to reduce the risks associated with a differing tier of ‘best efforts’ we would ask that a uniform standard be utilized across providers and licensing specialist to provide for a consistency among expectations and provider performance.