[ d. e. ] Providers shall prepare and maintain unique person-centered [ progress note ] written documentation [ in the form of progress notes or supports checklist as defined by the service. These shall be ] in each individual's [ medical ] record about the individual's responses   supports [ and specific circumstances that prevented provision of the scheduled service, should that occur ] . Such documentation shall be provided to DMAS or its designee upon request. Such documentation shall be written [ , signed, and dated ] on the  day the described supports were provided. Documentation that occurs after the date services were provided shall be dated with the date the documentation was completed and also include the date the services were provided within the body of the note.  In instances when the individual does not communicate through words, the provider shall note his observations about the individual's condition and observable responses, if any, at the time of service delivery. 

Comment:  Add “Or” to options of when documentation shall be written.  The statements are conflicting and could be interpreted as a citation if note is not completed on day supports were provided.   

[ e. f. ] [ Examples of unacceptable Unacceptable ] person-centered progress [ note written documentation notes ] include: 

(1) Standardized or formulaic notes; 

(2) Notes copied from previous service dates and simply redated; 

(3) Notes that are not signed and dated by staff who deliver the service, with the date services were rendered; and 

Comment: THERAP allows for another person to enter note for staff member when given verbal input from the staff member, if the need arises.  Note includes who provided the service and how service was communicated.  Additionally, it is important to include electronic signature as acceptable for providers using EHR. 

(4) Person-centered progress [ note written documentation notes ] that [ does do ] not document the individual's unique opinions or observed responses to supports. 

Comment:  Individual’s unique options?  Confusing.  Does this mean opinion about their supports or opinions in general? 

[?13.?15. ] Perform criminal history record checks for barrier crimes in accordance with applicable licensure?requirements at §§ 37.2-416, 37.2-506, and [?37.2-600?37.2-607 ] of the Code of Virginia, as applicable. If the individual enrolled in the waiver is a minor child, also perform a search of the VDSS Child Protective Services Central Registry. The provider shall not be compensated for services provided to the individual enrolled in the waiver effective on the date and afterwards that any of these records checks verifies that [?the provider has been convicted of barrier crime, as is applicable to the provider's license, or if the provider has a finding in the VDSS Child Protective Services Central Registry (if applicable).?the staff person providing services was ineligible to do so pursuant to the applicable statute. 

Comment:  We do CPS checks for people providing adult services, is this necessary? APS checks make MUCH MORE SENSE for adult services.

[ 19. Providers shall document and maintain written semi-annual supervision notes for each DSP?and supervisor of DSPs that are signed and dated by the supervisor. Additionally, 

Comment:  Is this requirement only for DD Waiver?  ID Waiver has not had this requirement.