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12VAC30-122-310. Community coaching service.

A supervisor meeting the requirements of 12VAC35-105 shall provide supervision of direct support professional staff.

This standard is excessive and should not be put into regulation. Each Waiver provider currently performs monthly supervision with their staff that follows the expectations of their organizations policies. Adding the additional burden for waiver supervisors to complete the below mentioned task as a part of their monthly supervisory notes exceeds standards applicable to clinicians, administrative personnel, and all other health related services in DD, MH, and hospital systems.

Supervision is not just about the employee’s performance, but necessary supports, mentorship, professional development, employee needs, and other issues addressed by the supervisor or employee as needed. This requirement is too prescriptive and limits the purpose of the supervisory session and should not be put into regulation. Supervisor’s should be required to have records of their supervision that meets the standards of their organizations, and not be dictated to but any funder. A requirement to document monthly to document is excessive (A_D) for this service

E. Semiannual documentation by the supervisor concerning the individual's satisfaction with service provision. - excessive as supervision is not about the individuals served but the employee who is being paid by the organization. Supervision should not be used as a satisfaction survey or instrument.

Submitted by Cil Hurd - Burks

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