In review of the updated competency checklist for DBHDS Licensed Providers that has been sent out for public comment, I take a minute to pause and really think about the true intention of this checklist. In review of the independent reviewer’s most recent report and prior reports, the following within section V.H.1 of the report is noted; “The Commonwealth shall have a statewide core competency-based training curriculum for all staff who provide services under this Agreement. The training shall include person-centered practices, community integration and self-determination awareness, and required elements of service training.”

I know that the increased competency requirements that Providers have witnessed throughout the state is a direct result of the outlined requirement that the state must uphold; however the way in which this can be tackled is not felt to be through the completion of checklists.

• It is in this commenters thoughts that a true training curriculum, similar to the current DD Waiver Orientation Exam, is what the state is needing in order to demonstrate staff competency. The use of checklist, no matter the updates, continues to be left at the discretion of the person who is completing the form, and does not formally serve as a true identifier of a person’s ability to provide genuine person centered services. Due to the nature of the work that we do within the service delivery setting having ongoing training and hands on with each direct support professional is something that takes place and does occur; however the use of multiple checklists and requirements for completion get in the way of this process. A more streamlined measure of accurately capturing the knowledge base of the DSPs who currently provide services throughout the state of Virginia needs attention. The development of training material by the department is what is needed. As agencies are left with this requirement, this allows for inconsistency in the information that is being developed and shared. Having a central training curriculum, videos, and testing would allow for DSPs to transition from agency to agency without the need to retake material, etc.
• Ultimately, the use of checklists to outline a person’s competency is not a long term way in which the state can remain in compliance with the Settlement Agreement section outlined above.

Additionally, the new guidance material indicates that the 8 page document would require additional processing in the amount of two or more times through each DSPs personnel file, as the Competency 3 section is required prior to service delivery in the absence of a proficient staff person, which would indicate that this checklist must first have section 3 completed and verified and sections 1 and 2 completed within 180 days with proficiency noted during that time frame as well. This appears to be a focus away from service delivery and more on the completion of a checklist, that may or may not accurately outline the skills of the noted staff, due to the implications that are present if this form is not present or not completed as it is should be.

• The noted requirement for a complete retest of the DD Waiver Orientation Exam for DSPs who do not demonstrate proficiency within the 180 required days is not appropriate, in that having a DSP retake an exam that they have successfully passed appears to be disconnected. The system in which these competencies were designed appear to overlook the reality of true service delivery. As Provider agencies, we want our staff to demonstrate competency in the care that they provide; however the current system in which these are implemented is not the appropriate answer.
• The final note in review, pertains to the reevaluation of competency, it is unclear as to why a repeat of proficiency/competence is needed after the DSP is determined to meet the requirements. In reality, if a DSP meets competency on day 140 then why would they not meet that same competency on day 366.

We as Provider Agencies are open to meeting all requirements; however in working directly with the current system, it appears to be a consensus that changes are needed, as the way in which additional checklists and requirements continue the end result is not aligning with the outlined goal.