In review of the updated competency checklist for DBHDS Licensed Providers that has been sent out for public comment, I have the following comments:

I understand that the state is responding to requirements set forth by the DOJ to ensure that the needs of those receiving services are met by qualified staff/professionals.  However, using checklists adds an administrative burden to agencies that takes away from the personal support and care that is provided.

               It would be more beneficial for the state to utilize online training documentation that can be completed and utilized across agencies to ensure a more thorough and consistent knowledge base when serving those in the state of Virginia.  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.

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.  Then potentially 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.

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 proficiency in the care that they provide; however, the current system in which these are implemented is not the appropriate answer.

Finally, with regards to 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.

Provider Agencies around the commonwealth are more than willing to maintain compliance based on the regulations and requirements.  However, we seek to have meaningful ways to achieve said requirements and do not feel that increasing the amount of administrative requirements increases the care provided to those receiving services within the state of Virginia.