| 1. | 106-20 | Definitions |
Comprehensive assessment means a comprehensive and written assessment that updates and finalizes the the initial assessment. Comment: The comprehensive assessment is completed for most agency's in same day access. The definition suggests two separate assessments which another assessment may not need to be completed within 1-2 weeks of receiving services. The initial assessment is the comprehensive assessment. Serious Incident: Level II item #4 needs to clarify a TDO or an unplanned medical hospital admission. Level III item #3 is removed - is this intentional? Serious Incident 4. An unplanned psychiatric or unplanned medical hospital admission of an individual receiving services other than licensed emergency services: Comment: Need to reconsider the reporting of unplanned psychiatric hospitalizations as this is part of the services provided by CSBs. Medication error - definition removed: Comment: Does medication errors not have to be reported? Page 12: substance abuse should be changed to substance use disorder |
| 2. | 106-70 | Renewals | F. Failure to submit a completed renewal application prior to the expiration of the provider's current license shall result in the closure of the license. Comment: Should a grace period or a warning be in place prior to closure of the license? |
| 3. | 106-110 | Compliance | 3. All applicable federal, state or local laws and regulations and all applicable department guidance including: Comment: The guidance documents are not regulations and shouldn't be added to the regulatory requirements. |
| 4. | 106-120 | Corrective Action Plan | Regulation does not specify time frame for Licensing Specialist to return the approved CAP or notify if not approved: Comment: Recommend adding a time frame such as 15 business days. |
| 5. | 106-300 | Employee Training | Required initial training: within 7 business days following an employee or contractor's start date, each employee or contractor responsible for training regarding: CPR & first aid: Comment: Difficult meeting this deadline recommend to state "a person shall not work alone without CPR/FIrst aid certification. Most courses are scheduled and would make within 7 days impossible. |
| 6. | 106-400 | Mission Statement | Any time there is a change to the mission statement Comment: If the mission statement is updated on the website is this sufficient? If not, who is notified? |
| 7. | 106-570 | Reporting to the department | Recommend change the language to read root cause analysis shall be conducted by the provider within 30 business days. |
| 8. | 106-590 | C & D | Needs clarification as to what types of complaints are associated with licensing regulations that are not Human Rights. |
| 9. | 106-810 | Emergency preparedness and response plan | The provider shall maintain documentation of collaborative outreach to local emergency officials to include local emergency mangers at least annually: Comment: If CSB is part of a local emergency team with County/Community, what type of documentation is needed? |
|
10. |
106-700 | Floor plan and building modifications | Consider clarification on regarding service modifications (ex. siding on house, exterior painting, counter top replacement, etc.) |