Virginia Regulatory Town Hall
Agency
Department of Behavioral Health and Developmental Services
 
Board
State Board of Behavioral Health and Developmental Services
 
Guidance Document Change: The new documents are designed to establish direct support professional and supervisor competencies in developmental disability programs licensed by the Department of Behavioral Health and Developmental Services, and a corresponding protocol, and are intended to address concerns identified by the Independent Reviewer for the Settlement Agreement.
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11/8/19  3:24 pm
Commenter: Holly Rhodenhizer, Lutheran Family Services of Virginia

Competency Comments
 
  1. Page 2 – Providers of Individual and Group Supported Employment services are also excluded due to operating within organizations that meet Commission on Accreditation of Rehabilitation Facilities (CARF) standards. – Would this stand for Residential and Day Support programs that are CARF Accredited as well?
  2. Page 7 – Competency 3 and all related skills must be confirmed as competent prior to providing support in the absence of paid staff who has demonstrated proficiency with this competency. – This will negatively impact Group Home, Community Coaching, Community Engagement and In-Home as the DSP’s cannot provide billable services alone prior to competency. These service lines do not fund adequately based on two staff providing the service. We cannot maintain fiscal viability to hire, train and provide each new hire with a second staff member or supervisor for all shifts until the employee gains competency; however, we provide drop in support from supervisors with new hires as well as support through our on-call system when needed. While we agree that there would need to be a competent DSP or Supervisor available during critical times until competency is established, we should not be required to provide the two staff at all times. We also continue to have a DSP shortage crisis across the state which would add another layer of difficulty with having enough people to maintain this requirement.

    1. Competency Document:
    2. Page 5 – 3.2 Provides medication as prescribed – We would not allow someone to dose medication until they were competent; however, they could work alone and not perform that job duty.
  3. Page 7 – From the date of that initial 180 day review, 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. – We would not be able to maintain an employee who is not able to provide billable services; therefore, we would have to separate any employee who is not able to demonstrate ongoing competency. This would further add to the DSP shortage crisis. We would like to suggest a grace period where services are billable while the employee is undergoing retraining to rebuild competency.
  4. Page 8 – Training may be accessed through a variety of means as long as it is nationally recognized or developed or approved by a qualified professional in each competency area. – Many providers in this field have well educated professionals that have the capacity to research and develop quality training; however, they do not have titles on your approved list. Not all providers have the financial stability to hire these professionals. Would DBHDS be amenable to developing the training for all providers to utilize?
  5. Page 9 - Autism professionals include – Please add Positive Behavioral Support Facilitator (PFSF) to this list.
  6. Page 9 – The following topics must be included in training provided to DSPs and their supervisors when supporting individuals at SIS© tier four – It would be helpful if DBHDS developed all training to ensure it includes all mandated topics and is developed by the proper professionals without adding further unfunded mandates on providers.  
  7. Page 10 - These checklists must be initiated by DBHDS-licensed providers and DSPs and DSP supervisors confirmed as proficient within 180 days of hire or within 180 days of accepting a person with related SIS© tier four support needs when no individuals were previously supported by the provider with these needs. – What is the time frame for someone who moves to a Tier 4 from a lower tier?

 

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