As a provider that is a Department for the Aging and Rehabilitative Services vendor, which has held a national three-year accreditation from the Commission on Accreditation of Rehabilitation Facilities (CARF) for over 30 years, we are intrigued with the new content of chapter II of the provider manual.  However, as a surveyor for CARF myself, this option of substituting the three- year CARF report with no recommendation around the staff competency training, in lieu of DSP training focused on developing specific competencies, seems to be less effective at providing direct service staff with the tools needed to be successful in serving this population.  CARF accreditation can and is granted to organizations who serve a multitude of individuals, not just individuals with disabilities.  Furthermore, the standards that CARF has on competency training are not one in the same with the DSP training and the CARF standard can be met in many ways.  Therefore, in our opinion, it is not in the best interest of the person receiving services, nor the direct service provider staff, to not receive the more robust DSP training. 

We are expressing concern for how providers would address skill development, job knowledge and industry best practices of DSP staff if they do not have this training opportunity.  Generally, DSP front-line staff earn one of the lowest wages in the industry, due to reimbursement rates.  Recruitment and retention for these positions has also become increasingly difficult.  Credentials or certification and experience is essential to raising the level care to the individuals served by DSPs.  

Specifically, we would request that the manual content be further elaborated to specifically identify: (1) the process by which providers must submit the results from their CARF surveys including recommendations received to the Department of Behavioral Health and Developmental Services, (2) the process that DBHDS will verify that there are no recommendations for the standards that address staff competency and communicate this approval to providers, (3) the process and consequence that DBHDS will apply for a provider who has one or more recommendation(s) in an area of competency training in their CARF survey (for example, is a recommendation competency based safety training not acceptable or is this specific to standards in sections 2, 3 and 4 of the standards manual) , and (4) further clarification on the applicability of the first sentence of this paragraph in the chapter, to the later sentence regarding CARF accreditation, as the use of furthermore appears to imply that one is reliant on or a pre-requisite of the other.  The word “competency” utilized by CARF, appears to be vastly different from the intention of the competency training as currently required from DBHDS of providers (e.g. DSP training).

Thank you for the opportunity to provide comment and consideration to this feedback.