Thank you for the opportunity to comment on the Updated DSP and Supervisor Competencies Checklist.

1. “Evidence of training or education must be maintained for each individual and can cover one or more competencies as long as course content includes related information.”
   1. More guidance is needed on what is appropriate “course content”. The provider does not have enough information to make this determination based on the information provided. The risk of not clarifying what is appropriate “course content” could result in a significant claw-back of funding if DBHDS/DMAS disagrees with the provider.
2. Evidence of training should include both academic credentials, and specific professional credentials that follow the DSP (e.g., RBT, CNA, etc.). Providers would have an incentive to recruit those who possess valid credentials. This would save them time and resources that would normally be applied to training and supervision (i.e., time that is currently not billable/reimbursed). Most importantly, these credentials would follow the DSP; and providers would no longer have to re-train and re-attest that competencies were met.
3. The Implemented Skills (tracking) column needs more clarification. What is meant by:
   1. “communicate a fundamental education of the skill or action”? How do you observe/measure “fundamental education”?
   2. “high level of supervision needed”?. What does “high level” look like?
   3. “in the process of establishing the ability”? What does this look like?
   4. “moderate level of supervision needed”? What does “moderate level of supervision” look like?
   5. “not on a routine basis as appropriate to the skill or action”? What’s the frequency of a “routine basis”?
   6. “low level of supervision needed”? What does “low level of supervision” look like?
   7. “minimal supervision needed”? What does “minimal supervision” look like?
4. Elements of Competency 3.0 may not be applicable to all providers. For example, some providers may support individuals who self-administer their own medication, prepare their own meals, and who do not use adaptive equipment. Therefore 3.2, 3.3, and 3.4 would not be relevant competencies for this provider. The language present in Competency says “must be confirmed” without any option for N/A.
5. Competency 3.6 is incomplete. The “Observation (Indicators)” column appears to have left out some information: “Provides two examples, (one m…”
6. Since Competency 3 needs to be completed before a DSP can work alone with individuals, why not move it to the top and renumber it as Competency 1?

Thanks again for the opportunity to comment on the proposed DSP/Supervisor Competency Checklist.