The DSP Checklist is another hurdle to find Caregivers.  We have enough trouble trying to find attendants as it is.  If DSPs are required to do a checklist, then nobody is going to go into the Caregiving field due to DMAS and DPHDS not paying enough and making more regulations, therefore people with disabilities will be forced back into institutions which is a violation of our ADA rights to live in the least restrictive environment possible.

DSP and supervisor competencies should include a demonstrated knowledge and understanding of the regulations regarding abuse and neglect, and knowledge of the signs of abuse and neglect, under Competency 3.

The proposed checklist is easier to identify areas of monitoring/training for staff. It also allows our agencies to identify new training areas (as needed) to ensure compliance and staff enrichment.

Given the exponentially high rates of abuse of people with disabilities, DSP and supervisor competencies in section 3 should include demonstration of skills mastery in understanding dynamics of abuse, recognizing, responding to abuse and in fostering healthy relationships. These are skills that are useful in a lifelong human services careers,  and especially for supporting people with disabilities.  

 

 

While we do have to be aware of competencies and potential weakness to identified for training/retraining so that DD individuals are safe from abuse or neglect, this would be a better tool if developed into a once-a-year online competencies test.  From that test, strengths, weaknesses and areas that need addressed can be identified, the situation becomes a pass or fail. In addition to centralizing the data with the department, the needed reduction in time and paperwork for the provider(s) is realized and more focus can given to the DD individuals being served as opposed to the ever growing burden of paperwork. . 

The competencies checklist should include useful training targets for providers, including but not limited to, CPR/First Aid, TOVA (or other approved behavior management training), Med. Tech, Human Rights (esp. abuse, neglect), etc.  The checklist should be usable for the providers, and help keep track of important certifications, not just another checklist that must be completed.  An electronic format, maintained by the state, would also be a welcome change.  Realistically speaking, some of the soft skills required in the checklist may take 6 years to perfect, not 6 months.  Many of our DSPs are inexperienced and may require a lot of time in our field before they understand the nuance asked for in the checklist.  Ultimately, we feel this checklist will be a hollow exercise that serves to cover up more problems than it reveals, and will further separate the record keeping required by the state from the actual reality on the ground.  

The disAbility Law Center of Virginia appreciates the opportunity to comment on the Updated DSP and Supervisor Competencies Checklist (DMAS Form P241a). People with disabilities frequently encounter abuse and neglect, and this should be acknowledged in this document. We believe that Section 3 of the Checklist should include a requirement of understanding dynamics of abuse and neglect, as well as recognizing and responding appropriately to abuse and neglect. Understanding how to respond appropriately to these events will provide better protection for individuals with disabilities.

I understand the idea behind the form and the intent. However, this is an added burden to providers already running on skeleton crews, dealing with high rates of attrition (low pay and a pandemic), and over-inundated with daily paperwork as it is. We are a small provider and spend many hours providing direct care to the individuals we serve. In all honesty, I do not think that the checklist is a true indicator of competencies. It is another form that has to be completed... Do you want excellent individual care or a boat load of paperwork to document and check boxes? All these forms do is take time away from the individuals that we service. Agencies should be hiring qualified candidates to provide services and providing them with the orientation trainings, required yearly trainings, and supplemental trainings to keep them up-to-date, abreast of changes, and competent. Instead of adding to all of the task providers have to complete, how about revising what is already in place to achieve the goal behind the competency checklist. Please remember this is one of four competency checklist that providers may have to complete for each employee (full-time, part-time, or PRN). I beg that you revisit this requirement and come with an alternative (electronic, not another form(s)) or create a team composed of providers to offer an alternative measure. Please don't continue to bog providers down in an array of paperwork. Individual care, safety, quality of life, growth, and progress are what are important and paperwork should be a tool used to capture the wonderful work that providers do; not make it harder for us to do those things. I do hope and pray that this forum is not for looks and that the comments that are left here are read and truly taken into consideration. 

Agree with comment made by:

Warren J. McKeen, The Arc of Augusta

5/25/21  1:23 pm

In the meantime, we need clarification on whether Supervisors must write comments or not on this form, especially if provider has monthly documentation from Supervisors on staff observations.  

We have no argument about the content of the checklist for Competencies 1, 2, & 3 - generally accepted as skills that DSPs should be able to master and demonstrate.  We do, however, continue to have significant issues with the implementation of the requirement:

The terminology continues to be challenging - the term "competency" does not reflect adequate performance and "proficiency" is (after the first 180 days) the bare minimum required. 

Evidence of training should include academic credentials; course curricula are rarely available.

"Billing under the DD waiver must cease when competency requirements are not met initially after 180 days (or annually upon review) and may resume once competencies are confirmand (or reconfirmed) as indicated by signatures and dates signed below."

The above statement (at the end of the check list) neither reflects the current regulatory language nor is appropriately placed on the form - it appears directly above the only place to sign the completed form which should be done upon initial completion and not when a requirement is "not met." 

 

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.

Additionally...

Competency 3.1 states, "Conveys a basic understanding of the health information for the people they support". Then, the "Implemented Skills (tracking)" column lists, "basic understand, developing, and competent". Is there a need for "developing" or "competent" if the competency only requires a "basic understanding"? Not sure how this is measured. Also, what does "convey" mean? What does this look like?

It appears that competencies 3.6 - 3.13 are missing from the Town Hall General Notice? Providers are unable to effective commentary on an incomplete General Notice. For example, earlier comments referred to a need to include competencies for abuse, neglect, and exploitation. It appears that this is covered in the "missing" competency 3.12.

Why not add language from the Waiver Regulations regarding when a DSP is found "deficient" and the time frame that a provider needs to "begin remediation" (i.e., with 7 calendar days)? I think adding this information to the Checklist would be helpful (i.e., providers know what the expectations are for how to "remediate" deficiencies. 

 

Thanks for the opportunity to comment. One of the genuine challenges is to ensure the integrity of the identified level of ability based on the time spent in observations in addition to other job-related requirements. It can be a useful training assessment tool if implemented as purely intended. "Agencies with DSPs or DSP supervisors who have failed to pass the orientation test or demonstrate competencies as required will be referred to DMAS Program Integrity for consideration of additional actions." What are those additional actions? Also, is there consideration for a competency checklist specific to the level of functioning of individuals served by a provider?

1. Was section 3.7 – 3.13 removed?
2. There is a financial burden involved in hiring employees who cannot provide billable services until they are deemed proficient. All jobs require a time period where the employee will learn and become competent/proficient in their role, we would expect the same for anyone hired to perform a DSP role. The sponsored residential service will be challenging to operate if we have to ensure proficiency prior to placing someone in the home as this is a very personalized service. At times, we provide emergency placements, how would we ensure section 3 is completed correctly in a crisis situation?
3. Will DBHDS and/or DMAS provide the necessary trainings to develop competency and proficiency?
4. Is simply checking off that each item was observed sufficient, or will we have to provide evidence of each item.
5. Comment periods have become a method of formality and not actual consideration of providers’ feedback. The impact on the provider has not been considered when rolling out the new competencies. It would be beneficial to include providers throughout the state when developing items that have significant impact financially and programmatically.