We have no argument about the content of the checklist for Competencies 1, 2, & 3 - generally accepted as skills that DSPs should be able to master and demonstrate.  We do, however, continue to have significant issues with the implementation of the requirement:

The terminology continues to be challenging - the term "competency" does not reflect adequate performance and "proficiency" is (after the first 180 days) the bare minimum required. 

Evidence of training should include academic credentials; course curricula are rarely available.

"Billing under the DD waiver must cease when competency requirements are not met initially after 180 days (or annually upon review) and may resume once competencies are confirmand (or reconfirmed) as indicated by signatures and dates signed below."

The above statement (at the end of the check list) neither reflects the current regulatory language nor is appropriately placed on the form - it appears directly above the only place to sign the completed form which should be done upon initial completion and not when a requirement is "not met."