12VAC30-122-180. 

C5. If upon review a DSP or DSP supervisor does not demonstrate proficiency in one or more competency areas, then within 180 days of this review the DSP or DSP supervisor shall review the training information, and orientation retesting shall be completed achieving a score of at least 80% documenting proficiency in the identified area or areas. 

The orientation is a knowledge based assessment, while the competencies are both knowledge and action based. On many of the competencies, you are required to assess action and knowledge. Where I have found the deficiencies to be is in the action part of the competencies. Therefore, retaking the orientation test is not a valid way of training for action. Having state wide readily available online training tools for the competencies from department would be helpful. 

DMAS shall not reimburse for those services provided by DSPs or DSP supervisors who have failed to pass the orientation test or demonstrate competencies as required.

So if I am reading this correctly, if someone is not proficient on the competencies after the 180 days, I either have to fire them or they cannot work with individuals until they are considered proficient. Is this a correct understanding?