Core Competency Requirements: Pages 21 -22 do not specify that staff providing Individual and Group Supported Employment services require the DSP competency trainings; however, the DHBDS Direct Support Professional (DSP) and DSP Supervisor DD Waiver Orientation and Competencies Protocol issued in Mach 2020 indicates that these employees are no longer excluded from this requirement. If this is still the case, recommend including this information to improve consistency, or state that this training is not required for the purposes of billing DMAS.
The list of Allowable Activities for Individual Supported Employment (but not Group SE) includes development of work-related skills such as use of community resource, break areas, and transportation systems. Regarding the 25% intervention-to-client work hours indication, individuals who receive this funding typically have a higher level of needs. Therefore, setting a maximum of 25% may not provide the appropriate levels of support in an individualized service delivery approach. This can be compounded by reductions in work hours being offered, secondary to increases in minimum wage. The hours of work offered by employers should not be used to detract from meeting the needs of individual; please reconsider this.
Service Unit information does not specifically mention Customized Employment. Please clarify that this, too, bills at an hourly rate, as it is a form of ISE and bills according to the DARS fee schedule.
Group Home Residential: Page 153 specifies, “Each quarterly review will represent the quarterly data however, the fourth quarter will provide an annual summary in addition to the fourth quarter data.” Most, if not all, other services do not have this additional requirement for the fourth quarter data; rather the “Four written reviews span the entire ISP year.” As each quarterly review is to be provided to the Support Coordinator, there is no additional benefit to the individual or the team indicating a need to single out Group Home Residential for this additional documentation and inherent administrative burden. Please rephrase so that expectations for this service are in alignment with the established standard.
General Requirements: Setting establishing a requirement that “If more than one service is provided, the record will be divided by service” does not take into account the framework of electronic health records and the underpinnings of data in those records. Providers of multiple services are generally larger and more likely to already be documenting in an electronic health record. The later point is of particular relevance to CSBs, which must submit data pulled from those records to DBHDS. While documentation should be easily identifiable as being germane to a particular service, it is not realistic or appropriate to have distinct records when one individual receives multiple services. This is inconsistent with DMAS’ approach to other (e.g., behavioral health) services, where there is clear recognition of shared access to information.