12VAC35-110-80. ISP requirements.

D. This puts the case manager responsible for other provider's implementation.  Disagree with this statement.  The Case Manager is responsible for determining the individual's satisfaction with services, needs for additional services and assisting with problem solving issues.

E. Concern about use of "detailed" here---there is an overarching push to have detailed individualized protocols for everything---while the service practices can address overarching health and safety concerns.

12VAC35-110-90. Reassessments and ISP reviews.

E. Must include documentation of the review will be in the file within 30 days after the end of the quarter to allow time for case manager to receive and review other provider's quarterly reports, which must be completed 15 days after the end of the quarter.

12VAC35-110-110. Enhanced case management contacts.

The way this is written it would apply to all types of case management, not just DD/ID.  This is problematic..

1. Should indicate "unplanned" interruption of service.  We have individuals who plan to stop services for a time and this should not trigger enhanced case management.

If an individual has lived in the setting for more than a year, then this criteria should not apply with regard to training center transition and congregate care setting as a reason to have ECM..