108-50 – Please define waitlist. Please define how long a person needs to be on a waitlist before a secondary screening is to be completed (for example is a person on a waitlist for 10 days – do they need a new prescreening?) If a wait list is defined as long than 30 business days prior to being opened for services you may not have to define how long they have to be on the waitlist for a secondary screening.
108-60.F.1.g -- please define risk factors.
108-60 f.2 c thru e – please remove as these appear to be medical in nature and more aligned with residential or inpatient services and not appropriate for typical home and non-centered based services
108-80 B.7 – Please define a “safety plan”. Is this required for all individuals regardless of disability type and/or ability to accept their own risk? Please define “identified risk”. How do we reconcile the requirement of a “safety plan” in an ISP and persons served having control over their own plan and not wanting to include items that they are a risk to themselves or others? Should “if appropriate” be at the beginning of the sentence and not just addressing a fall risk plan?
108-80.E – This feels like a regulation aimed at group homes exclusively and not for every home and non-centered based service. Should this be specified as to which populations it is aimed at? Please define what is expected as part of a training on someone’s ISP. Please define how an organization is to test for competency or knowledge… is that a written test? Is that an assessment by the supervisor? Is it a practical demonstration? Tracking the competency in the “personnel file” will make personnel records unwieldy and difficult to navigate and result in PHI being included in personnel files and will put a huge burden on HR and QI staff to track and file. Overall, while we do agree that staff members should be generally knowledgeable about individual’s treatment plans, expecting providers to “train and test” staff on service plan is unrealistic and conflicts with providing services. For example, a program such as ACT may have up to 120 (or more) clients involved at any one time. Finding a way to train and do a “competency” test for each of the 13+ staff for 120 clients results in in over 1560 competency tests just within that program alone let alone every time a plan is updated or modified throughout the year resulting in a reduction of time available to provide services. The unintended consequence of this regulation will most likely be less individuals plans and fewer modifications and updates to plans to avoid having to train/retest 13 staff.
108-90.C – please remove as there are not medication only non-centered based services
108-100 – please clarify that this is not stating that every service a provider is licensed for needs to utilize the same note form and is aimed at ensuring that all notes within a service look the same
108-100.B.5 – will there be problems with DBHDS if what was documented in a prior session to be the focus of the upcoming session does not happen due to life circumstances?
108-100.C – please correct to say the provider shall include documentation in the record should the individual no longer need the intensity of care of the specific home an/or centered based service.
108-110.A.5 – please clarify that this is only in regards to any tests, exams assessments, etc. that are ordered by a medical provider employed by the organization and not any outside medical needs that have been ordered by providers
108-120.C.5 – please remove outpatient and inpatient as these are centered based services and therefore do not belong in this chapter.
108-120.C6 – please remove PSR services as these are centered based services and do not belong in this chapter.
108-120.D – please remove as this is specifically regarding residential services
108-160 – What is involved in getting obtaining approval from DBHDS re: emergency plan? Please indicate who is responsible for approving these plans (Licensing or HR or both) and what the time frames are in regards to getting feedback back from DBHDS about these plans.
108-220B – how does telehealth impact these “face to face” aspect of the regulations if telehealth is allowed by the DMAS after the PHE?
