In response to the proposed serious incident guidance and those regulations affected herein, we wish to convey the following concerns and or considerations: 

• Since the IMU service has not rolled out to all regions perhaps this should be delayed until such time that DBHDS is able to uniformly hold every provider to expectations.  Larger providers may serve several regions and keeping programs in congruence becomes increasingly difficult with the differing needs from DBHDS.
• Office of Human Rights and Office of Licensing have two separate timelines for CHRIS report entry.  Because a serious incident report requires the number of the Human Rights report, there is a possible confusion or breakdown.  Since no one responds to serious incident reports that are entered over weekends or holidays, perhaps it should be considered appropriate to adjust the Office of Licensing’s timeline to match that of the Office of Human Rights and require that all reports are entered in CHRIS on the next business day.  This will allow providers to focus more on addressing the incident rather than ensuring time is made for paperwork, which can be completed on the next business day without issue.  The guidance clearly states that the IMU pulls reports on business days – providers should have the same courtesy.
• The expectation that CHRIS reports will be updated within 48 hours is unreasonable.  There are times when 48 hours pass and the additional information needed is not yet available.  This creates additional burden on the provider to go in and indicate that no further updates are available yet.  One example of this is entering COVID-19 test results which can take up to 5 days to receive once the individual is able to be tested.
• The IMU has not been consistently following the protocols for reaching out to providers with questions – recently we’ve had reports issued without engaging with us.  One such report was generated because of a clerical error that we could have resolved very quickly.
• Providers should be alerted annually to the contact lists held in DBHDS systems to ensure that they are consistently updated. 
• Progressive Action for Repeat Citations should not be in effect as of June 15^th, since the review of the document is not yet complete.  This should not go into effect until the document has had a fair review and providers of varying sizes should be included in this review. The information was sent out on June 3rd, a 12 calendar day (7 business day) period is insufficient to prepare providers for such a significant change that threatens their license renewals or applications.
• The inconsistency with which licensing agents address situations and issue citations will need to be addressed.  This has long been a concern of many providers.  Larger providers bear the brunt of this inconsistency, as well, due to needing to work with, possibly, several different licensing agents who all focus in on different things and interpret the regulations differently.  We’ve been told by licensing that this is not the case – but it is; if you look at the larger providers that traverse several regions, you will find that some have citations for the same things over and over and others do not review that portion of the regulations.