In regards to the description that “there is already staff in place to support this work,” referring to the significant increases in recent years for QA and risk management for each provider, we disagree.  Our agency has had to restructure and add administrative staff to accomplish the consistently increasing range of oversight requirements, such as, but not limited to: 24/7 incident reporting; increased oversight and quick turnaround with mortality reviews; documenting Root Cause Analysis (RCA) for every level II and III; the DOJ Settlement agreement oversight and reporting requirements; increasing performance contract and CCS3 reporting; and responding to multiple DBHDS staff from licensing, human rights, incident management, and mortality review (as opposed to focusing on collaboration with our local licensing specialist and human rights advocate); there also appears to be  increased demands to complete corrective actions at the time of the outcome of a human rights investigation, as opposed to working through a CAP process. We are faced with having to add more administrative staff who do not generate revenue, but whose costs are also not included in reimbursement rates, while also pulling more clinical or supervisory staff from direct work or supervision of direct work to complete increased quality management tasks. Although this is a comment on proposed regulation changes from DBHDS, please include that the context is one of managed care and the drastic increase in sources of oversight and lack of consistency across MCOs in order for providers to get reimbursement and be in compliance.  The whole context has a significant impact on providers--increased licensing and reporting requirements which require more unfunded staff time, decreases in authorizations (aka revenue), and decreased General funds.  

In relation to language proposed regarding reporting of serious incidents, please note that reverting back to prior language regarding reporting all ER visits in CHRIS will significantly overwhelm provider and DBHDS with unnecessary CHRIS reports and RCAs.  

Lastly, in relation to regulations requiring annual fire inspection by a local fire marshal, please note that it is not feasible for local fire marshals to inspect all provider sites across localities annually, if they are willing and understand the regulation to require their involvement.