Detailed comments have been provided directly to Les Saltzberg, DBHDS.  In summary, the following areas are of greatest concern:

• Allowing in certain services, years of direct experience to replace the educational requirement for supervision of staff
• Eliminating the requirement for a written plan for cultural and linguistic compentency as the relevant issues should be addressed in the individual's assessment and ISP
• Eliminating the requirement for a specialized fall risk assessment as the relevant issues should be addressed in the individual's assessment and ISP
• Change the requirement for the review of the of the ISP "at least every three months" to base the review dates on the date of implementation of the plan
• Require that a Transfer Summary be prepared only if the entire record does not accompany the individual to the new service/location