Other reviewers have made detailed comments on the specific problems within the document so I will not repeat the excellent points VNPP and Family Sharing have made.

The document should not be posted as an official Guidance Document. It could be used as a handout in a training on the topic with open discussion about some of what the document proposes and reality in interacting with the layers of reviewers within Licensing, Human Rights, HSAG, QMR, APS and the court system. There are multiple citations that would be given to providers if they followed what is recommended within some of the examples. APS would likely ask us to move individuals from the home and/or open cases to ensure individuals are safe.

There is some excellent information in here, but the document is riddled with problems that requires a re-write and review from multiple agencies.

The state system (agencies) that oversee provision of services, are not on the same page when it comes to the interpretation of the information within this document. DMAS, DBHDS, APS/DSS and others are not in agreement on all of the contents. Some of those agencies are not even in agreement within their own departments. Please do not post this as a Guidance Document.