Coercion was added to the January 2025 draft regs. If it remains in the next draft, we have the following comment: “Subtle language or actions intended to persuade or otherwise influence an individual to do something that they might typically be unwilling to do” seems subjective and overly general.  It could include some of the activities providers encourage to support plans, i.e., medication administration, hygiene, chores, etc. Could it include individual’s best interest be added to clarify intent?  Or remove the entire “subtle language” phrase. 

Complaints can be governed by the providers P&P’s, as not all complaints are required to be entered. Formal complaints are entered in CHRIS, otherwise, they are considered administrative complaints that are not entered and resolved at the program level.?? 

For Neglect, we recommend adding a sentence: “Neglect directly impacts the health and safety of an individual receiving services and has the potential to result in significant harm to the individual.”  This would help providers assess whether a medication error needs to be reported as neglect.  It would also align w/ similar initial internal review processes reflected in the guidance around peer-on-peer aggression.