On page 19 of the draft manual, under Documentation Requirements, Item #5 states:

5. There must be an ISP from each provider rendering services to the individual. The ISP is developed by the individual service provider related solely to the specific tasks required of that service provider and the desired outcomes. Plans of care help to determine the overall goals for the individual. The plans must state long-term service goals and specified short-term objectives in measurable terms. For case management services, specific objectives for monitoring, linking, and coordinating must be included.

There are 2 concerns here. The first is simple: "plans of care" is not the correct term for support plans for brain injury survivor. It was omitted in most places in the draft document when it was revised but it reappears here. 

The 2nd concern is the requirement that each provider must develop a separate ISP. This is not the accepted practice for ISP development. It is not how it works in the ID/DD waivers.

General best practices dictate that there will be ONE individual support plan (ISP) developed using a person-centered process by the Support Coordinator (Case Manager - CM). The process starts with assessment, followed by shared planning to develop one ISP. The one ISP is then shared with all non-CM providers chosen by the individual to provide the supports identified as needed in the ISP. Each of those providers then works with the individual & stakeholders to develop a Plan of Supports (called the Part V Plan of Supports in that system).

Please refer to Document DD01 from DBHDS, issued 6/7/21, "Person Centered ISP Guidance", Provider Development, Developmental Services, DBHDS, for a detailed overview of the process in the ID/DD system.

This language would result in the development of multiple ISPs. This makes no sense. It creates the possibility of conflicting ISPs, waters down the whole concept of an ISP, and will end up with a cognitively impaired individual sitting through multiple "person centered" ISP development processes resulting in multiple ISPs.

There should be ONE person-centered individual plan of support developed with the individual, their chosen circle of support, and any relevant other stakeholders agreed to by the person whose ISP it is. Strengths, needs, goals & wishes are identified & an ISP is created. Providers are chosen by the individual (from available options) to meet identified needs and those providers then develop, with the individual, a plan of supports based on the identified needs from the shared planning.

Multiple ISPs will only confuse a population with cognitive challenges by definition. It would be system-centered, not person-centered, to require multiple ISPs for one individual. I would personally go even further, given the cognitive impacts of brain injury & the frequency with which survivors report being overwhelmed by "walls of text" (long wordy documents that strain focus, attention & comprehension), and include a requirement that the ISP and Plan of Supports be summarized in a cognitively accessible manner (we use a plain language highlights cover sheet) & reviewed with the individual carefully to ensure it is understood. 

The one ISP is the raison d'etre of the Support Coordinator and a big part of the reason for the conflict of interest provision that case management cannot be provided by a provider of other HCBS services. Requiring all providers to produce separate ISPs really just returns the case manager's role to the other HCBS providers, creating confusion and potential conflict.

Cognitive accessibility is crucial when serving a population with cognitive deficits. Please don't single the brain injury population out for multiple ISPs when other targeted groups are not burdened with such confusion. One ISP, developed with the Support Coordinator/Case Manager, then as many plans of support as needed to address the needs and goals identified in the one ISP.