Hello,

My name is Bob Larkin. I am the Training Coordinator at Richmond Residential Services.  I have been using and training the DBHDS DSP Orientation and Competencies since their implementation.  I have reviewed the newly edited version of the Basic Competencies and wish to comment on them.

First, I do want to commend you on realizing that the original tool was enormous and a bit confusing.  Competency- based supervision is something that I do support. However , in the current environment of our work in Virginia dictates that we are very often hiring inexperienced workers that will accept the hard work and little pay.  At RRSI, we do an excellent job with new employee orientation, program specific training, health training, and crisis intervention including behavior observation and management.  It has been an overly ambitious requirement to expect a novice employee will become a competent professional in one year.  I fear that with DBHDS now expecting this to be achieved in 180 days agencies will simply not be able to utilize person-centered techniques and strategies to meet employees where their needs are and will lose many employees who might have had great potential to serve our individuals.  I have researched how NADSP Code of Ethics and Core Competencies are being addressed in states like New York and I would urge the Commonwealth to mirror their blueprint to achieve the desired outcomes.  It seems New York acknowledges that Competency-based supervision is more of an evolution for employees and not something that can be dictated nor punitive. .  If I understand the new DBHDS requirements of not allowing professionals to work alone until they are competent in Competency 3 will simply not be conducive with the current reimbursement structure under the Medicaid Waiver.   At RRSI we follow DBHDS regulations and will continue to do so. However as our industry faces stagnant rates, low pay, and a workforce that often needs to hold two to three jobs to make a living, planning to cover programs under the proposed requirement will force many agencies to close or not be forthcoming on their developing workforce.

My agency has struggled to achieve full competence in the supplemental competencies: Autism, Behavior, and Health.   I do acknowledge that for individuals requiring more intense supports that professionals will need additional knowledge and experience, however since DBHDS does an excellent job of pushing person-centered treatment, our workforce learns what they need to support the individuals in their care.  They work with experienced supervisors, directors, quality assurance, and training within their agencies and will community partners such as Behavior specialist and Health care professionals.  The new expectation that training in these supplemental requires the hiring or purchasing of training offered by professionals such as Registered nurses, Psychiatrists, and Board certified professionals is an impossible expectation for any non-profit agency who have not seen a Medicaid waiver rate increase in over five years.  I would think a better solution would be to make sure the training curriculum utilized by an agency met your DBHDS standards.

It appears there is come inconsistency in the requirements for the supplemental ratings.  On page 8 of the protocol document it states that Basic competencies are for SIS tiers One through Four.  However it later states several times that the additional competencies have to be achieved when supporting individuals at Tier Four (page 9)

As to the tool itself, I suggest some edits to clean up the tool. There are breaks in odd places and the borders do not always line up.

I would be happy to support appropriate changes to the proposed document and to create a helpful plan to implement and monitor progress.