Consistent with our recommendation in our other comments, we propose replacing the term “assessment” throughout this section with “Comprehensive Needs Assessment,” or “CNA.”
We recommend adding a (C) in this section that reads, “If a comprehensive ISP that includes all the required items outlined above is developed within one business day of admission, an initial ISP shall not be required.” Given all the required elements in the initial ISP are included in the comprehensive ISP, we don’t believe providers should have to develop both, again, so long as the comprehensive ISP is developed within one business day of admission.
In the current (C) of this section, greater clarity is requested with respect to how frequently a provider must request a signature if the individual is not responding. While the regulations require a signature be requested at a minimum, each time the provider reviews the ISP, they don’t speak to how many times a provider needs to request a signature at any point in the process.
