On behalf of the Virginia Association for Behavior Analysis, we thank you for the opportunity to provide public comment on the Developmental Disabilities (DD) Waiver Complex Supports Competencies. Overall, we strongly support the state’s commitment to establishing clear, robust competency standards for Direct Support Professionals (DSPs) supporting individuals with complex needs. The draft reflects strong foundational principles; however, we encourage DBHDS/DMAS to incorporate two critical additions to strengthen implementation and improve long-term outcomes for individuals served:

 

1. Explicitly Embed and Define "Skill Generalization" Across Settings (in Accessible, Non-Behavioral Terms)

While acquiring skills in structured environments is essential, true independence and quality of life depend on skill generalization—the ability of an individual to apply learned skills across different environments, people, times of day, and natural community contexts. Currently, DSPs are often trained to manage behavior or support routines in specific, localized environments. To ensure long-term behavior change and functional communication, DSP competencies should explicitly train staff on how to support skill transfer into everyday life. Because DSPs come from diverse educational backgrounds, this concept must be articulated in clear, practical, non-technical language rather than behavior-analytic jargon. We recommend including language such as:

• “DSPs demonstrate the ability to support individuals in practicing and applying functional communication, coping strategies, and daily living skills across multiple environments (e.g., at home, in the community, with different staff, and during routine transitions).”

• “DSPs actively recognize and create natural opportunities throughout the day for individuals to use newly learned skills in different settings.”

 

2. Add a Dedicated Competency for Recognizing and Facilitating "Therapeutic Activities"

We strongly recommend adding an explicit competency that addresses identifying, supporting, and promoting participation in meaningful, age-appropriate, purposeful activities.

Engagement in authentic, goal-directed, and meaningful routines (e.g., independent and shared leisure activities, community engagement, structured daily living responsibilities) directly correlates with preventing, mitigating, and reducing challenging behaviors. When individuals are engaged in enriching, age-appropriate activities that match their preferences and strengths, non-functional or challenging behaviors are naturally displaced by productive routines.

We propose adding a competency standard along the following lines:

 

• Competency Requirement: "The DSP identifies, supports, and facilitates active participation in age-appropriate, meaningful, and purposeful activities tailored to the individual's interests, preferences, and goals."

• Observable Performance Standard: "DSPs proactively structure daily routines to reduce passive engagement (e.g., excessive downtime or non-interactive media) by embedding choices and opportunities for participation in community, vocational, or self-directed tasks."

 

Thank you for your dedication to continuous quality improvement within the Virginia DD Waiver system.