Please consider a 90-day grace period for Competency 3.2 (Provides medication as prescribed) being deemed competent if the provider has a policy for back-up provisions (ie. On-duty supervisor who is responsible) and the DSP is enrolled in a medication administration course.   We would not allow a DSP to administer meds until they are trained, but they could work alone being competent in all other areas of Competency 3.   

Please consider a hybrid learning approach for the competencies to provide a consistent basis for learning among all DSPs across all providers.   Online modules developed by DBHDS would provide a basic knowledge and ensure compliance with the DOJ.  This could be tracked and verified by DBHDS.  Skills checkoffs and proficiency determination would continue to be the responsibility of the provider.  

It should be noted that the training for staff needs to be addressed when the support need is identified for the individual, which may be several weeks in advance of a SIS update.

Consider moving Competency 3 to be first in order and proficiency being determined as the current Competency 1 & Competency 2 sections are verified and established as proficient over the 180 days.