“Training and competencies must be initiated by the provider upon notification of the individual’s assignment to level 5, 6 or 7 or the approval of the customized rate and completed within 180 days if the provider cannot show that comparable training specific to the needs of the individual has not already been completed.”  (Medicaid Memo – 9/1/2017)

This creates unreasonable administrative burden due to completing unnecessary and irrelevant training.  The specific needs of an individual may prompt an assignment to a higher level seldom wait up to 180 days to be addressed.  Also, the training needed for any staff must be addressed when the need is identified not when a SIS is updated!