Comment: This does not allow for least restrictive environment. Providers have operated for many years with staff that sleep. There are measures in place to ensure the individuals are cared for should the need arise. This doesn’t consider electronic supports that have allowed for greater independence. This will also force smaller group homes to increase the capacity of home to cover the costs of bringing in awake staff. This takes away from services being individualized based on the needs of the people in the home.
Comment: According to 12VAC30-122-120, providers cannot have a waitlist as they are expected to be able to serve within 30 calendar days of the referral. Is this regulation contradictory or are we misinterpreting 12VAC30-122-120?
Comment: this places an undue burden on the provider to show competency and is a duplication of effort. This will cause a significant amount of time to create ISP specific tests. We already document our training on ISP’s and ensure understanding of the needs of the person.
Comment: Does the provider or the Support Coordinator complete the reassessment? Is this a team effort?
Comment: Ratio’s shall be determined based on needs of the people residing in the home rather than a fixed ratio dictated by DBHDS. If everyone in the home sleeps through the night and doesn’t require intervention, it should be at the providers discretion to allow staff to sleep if safety measures are in place should the need arise. Management will continue to evaluate the need for staff changes based on the needs of the individuals.
Comment: Sponsored residential is an individualized service that serves a max of two people in one home with one sponsor. It is up to the sponsor to have designated staff that are available to provide supports when needed.
Comment: Please exclude Sponsored Residential from being required to have menus. Requiring menus in Sponsored takes away from this being a home like environment and makes it institutional. If the person residing in the sponsored home has a specialized diet, the sponsor will follow those dietary guidelines.
Comment: Physicians are rarely involved in private provider operations; it is doubtful they would be willing to sign off on these items. This also opens the door to discriminate against someone with a communicable disease. Perhaps a better regulation would be to ensure the provider puts plans in place to serve the person based on their needs while protecting the well-being of others served in the same program or residence.
Comment: Would an agency RN count as a medical professional according to this regulation? If not, it would be very challenging to find a medical professional willing to approve other agencies policies and procedures. Please also consider the many providers who do not have any medical professionals on staff.
Comment: Some program participants have the capacity to manage their own environments and should be permitted to maintain that level of independence. Please allow for a competency assessment to be completed, and if met, household chemicals would not need to be secured.
Comment: Please remove “and provide” from this regulation. The sponsored residential contractor is expected to maintain their own staffing arrangements.