As one of the people responsible for reporting for a large agency, I find the proposed reporting guidance to leave ZERO room for human error. I understand that DBHDS is trying to meet requirements from the settlement but these regulations will be an impossible standard to meet.
Moral of the story: this new standard is beyond what can be reasonably expected and creates an environment where providers WILL fail and be at an unnecessary risk of losing their license. Which, in turn, will affect the individuals that the provider serves.
Please reconsider this guidance document in its entirety.