107-10

Include the definition of Residential Crisis Stabilization Services, that matches forthcoming definitions being developed between DMAS and DBHDS. 

107-30

The service descriptions overall lack clarity and specificity. This is not clear the difference between each service. For example, what is the difference between A (clinically managed high-intensity) and C (clinically managed population-specific high intensity)? For D, what makes something a geriatric setting?

Perhaps for clarity providing a list of services that for each population category. For Example: Services related to Substance-Use disorder services. !. Clinically managed high-intensity, 2. Clinically managed low-intensity.

High-intensity residential services - What makes this a higher level than low intensity? What is the difference here between this and clinically managed population-specific high intensity?

It would be ideal if Supervised Living language matched the Waiver regulations (listed as Supportive Living in the Waiver regulations).

107-60 C

What constitutes a “medical screening?” What is expected? I would think this depends on the environment as a group home is going to be different than a medical screening of inpatients.

107-60.F.2.d

Revise to note provider shall attempt to obtain BAC or administer a breathalyzer, to reflect those individuals have the right to refuse and still receive services.

107-60

60.G - Thank you for recognizing that there are situations where the initial assessment meets the requirements of a comprehensive assessment and that an update is not required.  This increases alignment with DMAS expectations for many services.

107-60.H

Revise to reflect for a minimum of six years after the individual’s discharge, as other factors are affecting how long records must be retained.

107-70 D

Informed choice D.3.b. propose adding “as applicable” as there may not be alternative services available to the individual.

This information is not easily added to the ISP. How would a provide add this information into their outcomes and objectives? Many EHRs do not have the capability to attach documentation to the ISP. Progress notes often are not able to be “flagged” and those in residential have many notes and this information gets lost among the many notes.  

107-80.B.14

Change to projected discharge date “or” estimated length of stay, to reflect that some services are anticipated to be the individual’s home for many years.

107-80.C.2

Change to note to provide the ISP within 48 hours of admission.  As written, conflicts with 107-70, where A.1, A.2, and B stipulate that the initial ISP shall be developed and implemented within 24 hours of admission.  

107-80.E

While we agree that staff members should be knowledgeable about the contents of ISPs for individuals served, establishing an expectation to train and test all staff members involved with service delivery is an unrealistic expectation that will significantly detract from service delivery.  Observations of competency in and knowledge about providing services are part of the supervisory and evaluation process. 

Promoting this is likely to result in providers making fewer updates to ISPs, to avoid retraining and testing staff.  For short-term services, a person could potentially be discharged before testing of all staff members (typically three shifts) could occur. 

There is no realistic way to document this knowledge and competency without documentation of confidential information about individuals served, which should not be part of a Personnel File.  This also places an undue burden on Human Resources staff members who maintain personnel files.  File sizes would become unmanageable.  

107-90.C

Remove, as this is not applicable for residential services, which are inherently not medication-only in nature.

107-90 E.

Provide more information on what is required of changes to medical protocols.

107-90.F.5 and F.6

Rephrase to recognize that adults residing in Group Homes and ICF/IIDs often live in this setting for an extended period and the goal is to maintain functioning, vs. to progress towards discharge.

107-100.A

This is problematic. The format may be different depending on the service and the population served. The policy shall indicate where progress notes are located and the information to be included that is appropriate to the service being provided and the individual’s treatment plan.

107-B

B.1. This is not appropriate. The notes should be appropriate for the service and individual to document based on the service plan

B.3. What is meant by clinical staff and why is that delineation included here?

107-100.C

Revise to read that the provider shall document when the individual…

107-100 D

Progress notes should be documented to indicated services were provided by the ISP. (the shift should not matter)

107-120

Need to define the disasters. There could always be something new and seems this is another catch-all…what is it we need plans to address?

F. What is meant by local emergency officials and local emergency managers? This needs to be more specific

G. What does “medical record stewardship” during emergencies mean?

107-130

A.3. This is based on the individual’s ability to pay for services. We can arrange if there is funding available. If there is no funding, we cannot arrange for it.

A.4. Same comment as #3, it needs to be clear that the provider is not fiscally responsible for paying for the service. Additionally, if the individual or AR refuses, we will document the refusal.

107-150

Ensure consistent with DMAS requirements

107-160

If this will be the same regardless of the type of service, move to Chapter 106.

If not, then for 160.C.5 remove outpatient, intensive in-home, and day treatment, as these are not residential services and for 160.C.6 remove, as the services referenced are not residential services.

Input for ICF/IID staffing: The facility must provide sufficient direct care staff to manage and supervise clients following their individual program plans.

107-170.A.2

Add religious dietary requirements

107-180.

A.3 Specify an exemption for short-term programs that typically do not have individuals leave the milieu, such as substance use treatment programs 30 days or less in duration.

B. This seems to overlap with Human Rights regulations. Why is this stated here?

107-190

Are these curriculums approved by the Board of Nursing available? Where can these be located?

Revise 190.G to specify syringes with needles, as not all syringes have/use needles.

107-220.B

Add that transferring providers are expected to share recent TB test results promptly, to meet these requirements. 

Include that treatment was offered and include the individual's refusal of treatment.

107-260

B. This is not appropriate to keep cleaning supplies lock up for all living situations. It is appropriate for individuals in Supervised/Supportive living to have access to cleaning supplies based on the assessment given that staff are not there 24 hours a day. Having them secured limits an individual’s independence in this setting. Also, what is meant by gardening supplies and products? If it is an individual’s property, we can’t violate rights by taking from them. This needs to be worked through more.

107-330.A

Unless accompanying guidance will change, please revise this to 60 days, so that regulations and actual implementation protocols are consistent and clear

Needs to be consistent with 106-80.A