20 – Definitions

• Community Coaching – add following participating “or to support an individual  when there is an ongoing barrier to participation . . .”    [This is an issue of access to the Community Engagement service; individuals with chronic medical, sensory or mobility issues, challenging behavioral issues or a condition which is progressively more debilitating will be barred from Community Engagement as 1:1 staff exceeds the parameters of the service.]

• Progress Note – We support this definition as written and object to the variations contained in the Provider Requirement section as well as the variation written in the Sponsored Residential service description (See Comments for 530 and 120).

120 – Provider requirements

• A.5.- Strike “medically necessary services and supplies” and add “services and supports”
• A.6.- Strike “supplies” and add “supports”
• A.10.d- Strike “Such documentation shall be written on the date of service delivery.” [This is not in keeping with the definition of Progress Note]

200 – Supports Intensity Scale® requirements

• A.1- Delete “to 72” and add “or older” after “years of age.”  [If the SIS is only validated to age 72 then language should be added to automatically assign all individuals age 72 or older to Level 5, Tier 4; the text (Appendix D-1) from the most recent Waiver Application is:

“To assess other support needs, each individual 22 years of age and older has the Supports Intensity Scale® (SIS®) completed every four years or when the individual's needs change significantly.

• A.2.a - Change “three” to “four” to stay consistent with the CL application
• D - Strike entre paragraph
• Add a new D – “Requires that the results of the SIS be provided within 10 days of scoring in an understandable format and that the support coordinator be required to explain the results and implications of the SIS score and avenues of appeal.”
• Add a new E.- “An automatic, independent review of the SIS administration process and results when an individual’s SIS Score changes despite a lack of change in their health or other circumstances, upon request.”
• Allow for providers of services to request an automatic, independent review of the SIS results when results do not align with the individuals support needs as identified by the treatment team.
  
   

1. – Community coaching

• A- After barriers add “or to support an individual’s participation when there is an ongoing barrier to participation” [See definition]
   
• Provide the opportunity for a variance which would allow a sponsor provider family member to provide the service if it is determined that this is the best or only alternative.  This request would be submitted through the support coordinator to the PA Consultant at the time of the Service Authorization request.

320 – Community Engagement

• Provide the opportunity for a variance that would allow a sponsor provider family member to provide the service if it is determined that this is the best or only alternative.  This request would be submitted through the support coordinator to the PA Consultant at the time of the Service Authorization request.  

370 – Environmental modifications

• C.6.- We recommend that an exception process be put into place for the uncommon circumstance in which the expansion of square footage to the home (which is prohibited) is an incidental result of a modification that will enable the individual to remain in the home, e.g., a larger, accessible bathroom. Limits could be put into place for how much additional square footage would be allowable in an exceptions process.
   
• Allow individuals living in Sponsored Residential homes to access environmental modifications in their Sponsored Residential location when there are changing needs requiring such funding.  This would happen after an individual has been living in the sponsored home, not at the time of referral or admission to the home.

390 – Group home residential

• E.1.c- Change “at least a daily note” to “a Progress Note” [This makes it consistent with other requirements]
• Move C.3 under letter D [It is under this section in other service descriptions]

530 – Sponsored residential

• E.1.c.- Strike “confirming the amount of the individual’s time in service and”  [This has already been removed from Group Home Services and needs to be removed from Sponsored now that we have moved to a daily rate and not one based on hours of service.]
• E.1.c.- End of second sentence strike “at least a daily note” add “in a progress note” [This makes documentation consistent]

550 – Therapeutic consultation

• C.3- Strike “written preparation and telephone communication”