3.  Not all supervisors are providing training so are not the ones ensuring that the DSPs have passed the test.  They generally do not have access to the employees training record on a regular basis.  The person providing the training is the one responsible for ensuring the DSP has received the training and passed the test.  When a supervisor provides the training then they are responsible for ensuring this.    To put this responsibility on all supervisors will add an unnecessary burden to their role.

4.  It would be helpful to include timeframes for when initial competency checklists are due.