Suggestions for Further Improvement and Recommended Changes:

An electronic version would be more useful for several reasons, including:

·       The physical space for comments varies in the new paper draft version.  An electronic version would allow expansion of space only when needed plus allow for faster entry,completion and easier use when editing the document,thus 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.

Page 5 of 8 of DMAS #P241a - Competency 3

COMMENT:  Reconsider having two supervisory signatures.  In some cases, there may not be a second person available to observe and assess proficiency. This seems duplicative and again increases the administrative time and ability to efficiently complete the required paperwork. 

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.