We agree with previous comments.
In addition, please allow for qualifications of the Risk Manager to include relevant or equivalent experience and not be based solely on DBHDS training; and we would suggest broadening allowable sources of training. We would like to know how each Risk Manager's qualifications and training will be reviewed/approved.
This position and its increasing responsibilities are good practice overall, but is another significant unfunded requirement, that is not covered by reimbursement rates or state funding.