The following is in regards to the updated regulations that now specifies that quarterly review will be tracked from comprehensive ISP.

While this more closely aligns with requirements for Developmental Services programs, this significantly impacts how quarterlies are tracked for compliance in our Behavioral Health services. Our agency, historically has tracked quarterly reviews from the start of program admission with the date of the initial ISP. This allows for staff to clearly track when annual assessment and annual ISP will be due.  This also coincides with requirements for DLA-20 which must be done at assessment and on a quarterly basis. Staff will now be required to track due dates for their assessment, their annual ISP, their quarterly reviews, and their DLA-20 assessments separately as these services will not line up with the new guidance. This does produce additional administrative burdens on staff members and increases likelihood for errors in tracking and potential compliance issues.