Chapter II

Pg. 34 The expectation that incumbents possess all KSA’s at time of interview/onboarding seems unrealistic in today’s workforce and does not allow for those coming from varied backgrounds, geographical areas, etc. It would make more sense to allow at least 30 days to assess these areas or allow a way to develop staff that meet most of the requirements.

Pg. 36. It seems illogical to continue the separate treatment of ID and DD populations following the merger and waiver redesign. There is also the statement that CSB’s must contract with other entities. This should read “may” and will be increasingly difficult as the number of private providers dwindle. The Support Coordinator for DD population must have  a Bachelors but this is not specified in the previous section for ID Support Coordinators. Again, inconsistent. The following pages seem to apply to only DD population but I would imagine they probably apply to both but it is very unclear and meandering in content.

Chapter IV

Pg. 1 Diagnostic Eligibility- DSM diagnosis for Intellectual Disability still specifies age of onset as prior to age 18. In this section the age of onset only specifies 22 years of age. As there are separate reimbursement rates and other considerations where differentiation is necessary between ID and DD diagnosis it seems that there are two different age parameters required.

Pg. 8 First paragraph, last sentence. In current practice DBHDS staff enroll the individual in the slot in projected status, not the Support Coordinator.

Pg. 11 Currently we are not receiving an auto-generated Notice of Action Form. The Support Coordinator sends an appeal letter generated at the CSB level.

Pg. 12 Is this new change that an individual can be presented to a WSAC without being on the wait list?

Pg. 14 First paragraph- there is another reference to the SC enrolling the individual in waiver whereas that is currently done by DBHDS staff prior to the assessment of financial eligibility.

Pg. 20 Does the Provider Part V need to be maintained in the SC’s electronic health record as it is created and/or uploaded by the provider to WaMS and resides within that system?

Pg. 33 Specifies that individuals must be Medicaid eligible to receive ID Support Coordination. Does that mean that we cannot provide Support Coordination if the individual does not have Medicaid or eligible for Medicaid? We have individuals in that situation who need services but have assets and such that make them ineligible. We would charge on a sliding fee schedule.

Pgs. 33-39 Since the waiver redesign and merger of the waivers (2016) why does DBHDS continue to specify different sets of rules for those that are ID vs. DD? In our experience they should be viewed under one set of regulations.

Pg. 40-41 Why is reimbursement available to screen DD individuals vs. ID? Again there seems to be no reason to make such a differentiation as the waivers were supposed to have merged.

Pg. 42 Why is the ISP still required to be retained in the CSB record now that the ISP is fully available and completed in WaMS?

Pg. 53 For assistive technology clarification is needed on the exclusion of shipping, freight and delivery costs associated with AT. It does not appear reasonable that any provider would supply products at cost. These additional charges are typical of any type of purchase and necessary.

Pg. 64 Removal  or disposal is not allowable for EM, but it is standard that contractors need to remove and dispose of materials during construction.