COMMENTS DBHDS Staff & Staff Supervisory Competency Protocols/Check-List The process has been improved but further suggestions for improvement are needed. · The new version of the checklist is shorter and more concise (and no important subject matter was lost in condensing into this revision). As an example, according to our member organization that piloted the revised process, had spent almost three days in 2018 reviewing and completing the previous version of competencies while this new draft version was completed by the group in 2019 within three hours. · A specific improvement is the “Observation (example indicators)” column included in the new draft checklist. This helped those piloting the checklist to ensure that they were interpreting the competency correctly and consequently sped up the process since it eliminated the need to brainstorm when and how each competency was demonstrated. Suggestions for Further Improvement and Recommended Changes: OVERALL COMMENT: · An electronic version would be more useful for several reasons, including: · The physical space for comments varies in the new paper draft version. There are times when we piloted it that we wanted more space and there were other times when we needed less. An electronic version would allow expansion of space only when needed, resulting in an efficient final document. · This new draft has unfortunately NOT reduced the voluminous requirement of initialing and dating by the supervisor in each section, along with signatures at the end. We propose that electronic signatures at the end of the checklist document would be sufficient and we could eliminate the requirement for initials and dates in each section. DEFINING DIRECT SUPPORT PROFESSIONAL (DSP) Thank you for excluding professional staff of CARF accredited providers of Group and Individual Supported Employment services. COMMENT: Exclude Benefits Counseling - Certified Social Security Administration Community Work Incentive Coordinators (CWICs) and certified DARS Work Incentive Specialist Advocates (WISAs) should also be excluded from the definition of DSP and not required to complete the Level 1 Orientation Training and Testing as they are highly certified professionals that provide financial and benefits counseling not direct support. CWICs are further required to take 18 hours of annual continuing education courses specific to their certification. The Benefits Planning and Assistance Counseling service is not a service that is waiver or disability specific. OVERALL COMMENT – CHECK-LIST - COMPETENCY AND PROFICIENCY The ongoing issue regarding the competency checklist is that the level of skill, expertise and receptive ability that a DSP who may have just a high school diploma) is required to have prior to being able to provide care without the support of a proficient DSP present is arguably equivalent to that of a 2nd year college student. (the provider cannot bill without a "proficient" DSP present). These competencies are written from the perspective of highly educated people who assume that high school graduates will have the same academic capacity as they do to memorize, absorb and implement intense information. The educability of caregivers willing and available to do this type of work is generally limited to include those with no advanced education or training experience. Additionally, many individuals receiving services do not utilize enough hours to fulfill a 40-hour work week for the DSP. Therefore, DSP’s will likely have more than one individual with which they work. To maintain proficiency for 2, 3 or more individuals is difficult. Group homes have as many as 6 individuals that the DSP may be responsible for. Many DSP’s work additional jobs and have families to care for as well. The provider then, must staff the individual with 2 DSP’s – one who is proficient and one who is trying to achieve proficiency. In a group setting, it is more likely to be possible to have the ability to financially support this intensity of training. But it is simply not feasible for providers that provide 1:1 service to do this under the current reimbursement rates. COMMENT: Issue #1: It is unrealistic to believe that learning about all the needs and wants of individuals can be done as a sprint when it is more like a half marathon. Even licensed medical professionals do not immediately know all the care needs of a new patient. They start with basic information and learn the specific details over time. RECOMMEND: that the language be changed to allow for the “competent” level (vs. proficient) to be acceptable for a DSP to begin providing billable services. The definition of “competent” states “The individual demonstrates all of the skills or actions in column two, but not on a routine basis as appropriate to the skill or action; low level of supervision needed. Competency refers to the bare minimum required for acceptability.” RECOMMEND: The last sentence states: “competency refers to the bare minimum…”. This should be completely omitted or rephrased to say “Competency refers to the minimum requirements for acceptability”. Issue #2: There is nothing within the checklist that measures someone's ability to know what human rights violations are or how they are to be reported. We recommend to include under Section 3. Page 5 of 8 of DMAS #P241a - Competency 3 COMMENT: Reconsider having two supervisory signatures. The smaller programs and some group homes only have one supervisory level person assessing competencies and providing the training needed to reach proficiency. In some cases, there may not be a second person available to observe and assess proficiency. In Day Programs, this is an additional administrative burden for which we were not previously required and will add administrative costs. If we trust supervisory personnel to assess proficiency in other areas, this should be sufficient in this area of the competencies. COMMENT: Consider revising the competencies for Medical, Autism and Behavior (Forms DMAS #P201, DMAS #P244a; and DMAS #P240a) - to streamline these competencies. COMMENT: There is a concern about the required training for the Medical, Autism and Behavior competencies. There are not many certified training programs available and those that are available - have a cost to them. An additional administrative and programmatic cost not captured in the rate. Most providers do not have access to the professional lists who must sign off on the in-house developed training indicated. This is another disincentive to providing services to those with higher needs. OVERALL COMMENT - COMPENTENCY CHECK-LIST: There are three sections that should be considered optional and not be required for all DSPs or even all supervisors. In these examples of specific job duties, we contend that these requirements would NOT necessarily apply to all staff but might rather be reserved (and specified in job descriptions) to only staff who are assigned to provide these specialized supports: 3.2 “Locates medications and side effect information for all individuals supported, provides safe and accurate delivery of medication; reports unusual reactions, responses and behavior to the appropriate health professional immediately” COMMENT: While the last phrase of that competency (reporting unusual reactions) applies to all staff, there are some staff who never deliver medications so the initial phrases about locating medications and side effect information as well as the actual delivery of medications should NOT pertain to all DSPs and supervisors. 3.3 “Correctly follows nutrition plans and meal preparation guidelines including the use of thickeners, special textured food preparation such as pureed and chopped consistencies and uses the correct utensils for all individuals supported”. COMMENT: We again propose that not all DSPs and supervisors support individuals requiring this level of support. Even with the number of individuals discharged from Training Centers, these specific meal preparation guidelines are limited in applicability and providers should be able to identify (by job descriptions) which DSPs have both this support delivery (and therefore competency) requirement. 3.4 “Operates and maintains adaptive, orthopedic, and communicative equipment correctly” – COMMENT: Same comment as above: These competencies are essential when needed in specific job descriptions but should not be a requirement for all DSPs and supervisors.