8.2        What services will be available for youth who do not have a caregiver meeting the requirements of #2? (see also 8.4  #1(d))

9.2        Who makes the decision that the standalone EBP service failed to address the individual’s treatment goals adequately, where is this documented and by whom?

10.1     Where other services are recommended by the service authorization contractor (#9) or recommended (#7) who makes the referrals, arranges the details, meets with the individual, etc?   The provider is not compensated for, nor necessarily trained in providing.

Appendix 1 – Section 3.4

In comments on a previous version we specifically pointed out that “supervision documentation” should not appear in any employee’s personnel record – for so many reasons, that is contrary to good practice:

• Employee records must be able to be released upon request to an employee – and while they might review the records of supervision, they will likely contain information or references to information which should remain protected
• Employee records can and do become part of litigation about employment related issue and would be required to be release in their entirety, and
• Employee records are accessible to administrative staff of the agency responsible for Employee Relations, Payroll and related functions.

If this is to make these records more accessible for review by DBHDS or DMAS, then simply stipulating that they must be available within a reasonable time period upon request should be sufficient.

 5.3.2                 When Crisis Support is engaged external to the CPST agency (with or without their knowledge or referral) their engagement will be dependent upon the entity providing the crisis support, whether or not the individual has granted access and whether or not the entity providing support supports their participation.   In other word, totally out of the control of the CPST provider! 

The question then becomes how will the expectations of 5.3.2 be operationalized, who will be accountable for their implementation and who will monitor the coordination among services.  How will you know, and how will you monitor, and what are the consequences for non-compliance?