I don't think most providers would mind amending a policy to include "drivers will do a headcount (or otherwise make sure nobody was forgotten) at each stop" but if this is followed by a licensing specialist's interpretation that this is requires documentation each time this is done then it's just more administrative nonsense that gets in the way of service provision.  

We already check off and initial enough common sense in response to isolated incidents across the state.  Doesn't seem logical to require even more of that from licensed providers when the incidents that sparked this idea are likely coming from transportation providers that aren't licensed by DBHDS anyway.