Virginia Regulatory Town Hall
Agency
Department of Behavioral Health and Developmental Services
 
Board
State Board of Behavioral Health and Developmental Services
 
Guidance Document Change: The new documents are designed to establish direct support professional and supervisor competencies in developmental disability programs licensed by the Department of Behavioral Health and Developmental Services, and a corresponding protocol, and are intended to address concerns identified by the Independent Reviewer for the Settlement Agreement.
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11/13/19  5:47 pm
Commenter: Kim Black, Hope House Foundaiton

DSP Competency Comments
 
    • The manner in which the department has chosen to comply with the DOJ settlement requirement to demonstrate DSP competency has placed unnecessary and extensive administrative burden on providers. The competency tool  has not created a measurable increase in the quality of support provided by DSP’s.  
    • Even though scaled back, the competencies are burdensome and often irrelevant to measuring quality support during a time of national staffing shortages, there is not time to comply in a meaningful manner 

    • The requirement that supervisors complete the observation and evaluate competencies does not take into account the time required by supervisors to complete for all staff supervised.  

      • Staff who have been deemed competent should be supported by DBHDS in completing observations and evaluating staff competency.  
    • Only requiring section 3 of the competencies may lend to providers not valuing section 1 or 2. 
    • There is no clarification for providers so that they may determine which advanced competency checklist to use when evaluating staff. For example, when is the Autism Competency required as opposed to the Behavior Supports Competency? How will a provider know which checklist to use?  
    • There is no training provided by the department to providers that consistently and absolutely meets training requirements for competencies. 
    • The added training, administrative and documentation requirements for evaluating competency is not supported by the current reimbursement rate.  

    • How will in-home providers meet the requirement of observation without incurring significant expenses as observation will be done 1:1 as is the nature of in-home services.  

      • What if the person supported doesn’t want this administrative work that is NOT related to their plan of supports completed on their time or in their home?

 

CommentID: 76882