Town Hall comments/response to the

DSP and DSP Supervisor DD Waiver Orientation and Competencies Protocol.

Since the “Agency Director or designee” is completing the proficiency document and observations on the Supervisor; are there training requirements for the Director or designee? Are they expected to complete the Supervisor’s assurance test on the VLC website?

Who qualifies as an “approved and qualified trainer” for training DSPs and Supervisors who work with individuals who are a tier 1-3? What qualifications are needed?

Can a supervisor delegate the observations of DSPs performing certain tasks outlined in the checklist? Or do they have to observe all?

On page 7, the guidance indicates “Confirmation of training” must be maintained. Are dates and a description of the training sufficient? Or are certificates required?

The explanation of when services are billable (in the box on page 7) is confusing. One paragraph seems to say that a program can bill if the DSP is competent, but the last paragraph seems to indicate that billing cannot take place unless the DSP is proficient.

Also on page 7, is there a grace period for DSP to become proficient beyond the 180 days?

For an individual who is identified as a tier 4, more clarification is needed on which of the extra competencies are needed. It seems that the document (see page 8) is stating that all three extra checklists have to be completed for anyone who is a tier 4. It may be reasonable to say: The autism competency checklist should only be completed when the individual has a diagnosis of autism. The health competency checklist would only be completed when the SIS indicates exceptional medical needs. The behavior competency would only be completed when the SIS indicates exceptional behavior needs.

On the actual checklist, please consider moving health and wellness the first category instead of the third, as it is most important.