I have worked for profit and not for profit agencies over  the past 30 years. Most and I say most of the providers had set thier mission and goals  to provide servcies that would benifit the population they selected. Now I am unemployed because of lack of education, due to over the years I had directed, QA program to ensure that the staff had the KSA's to provide the best servcies.  I would have hope that the regulatory would have offered exsisting agencies insentives the EDU's from  thier community colleges and universities to train thier employees for a degree specified in the program  changes such as QMHP, PPQMHP with a specified time frame, but no the governbody had not taken individual(client) and the  personnel inconsideration; and now good dedicated, experianced workers are out of work and the individual's they serve our affected(will be). In the 90's  North Carolina offered such a program for those agencies who wanted and needed to follow the ever so human service demands with change. So, no I an many will be unemployed and I would hope they other will futher thier education a 2-5 year process and now current mental health professionial are going to be over taxed and this will affect the clients and force providers(private) to fold however if the underline goal is weed out strong verse not so strong agencies/companies well this will do it.

The changes to the regulation and standards are always needed and appreciated, but somewhere alone the way we have forgotten the underpaid, undertrained professional and the individuals they sevre "The Human Factor"

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Under  12VAC35-105-1200. Supervision, we recommend language that reflects that a supervisor have a visit with each individual a minimum of once a month. 

With regards to the educational requirements - equivalency language would be beneficial in order to continue to promote Direct Support Professionals and Supervision of Direct Support Professionals as a valued/valid career path.  In other words, education or experience equal to the educational requirement.  It is important to maximize the amount of talented, skilled, passionate professionals in the field of disability services.  Current proposed language may limit provider's ability to hire/promote individuals that are capable and would provide value to the population served. 

Proposed revision to include equivalency language:

Detailed comments have been provided directly to Les Saltzberg, DBHDS.  In summary, the following areas are of greatest concern:

• Allowing in certain services, years of direct experience to replace the educational requirement for supervision of staff
• Eliminating the requirement for a written plan for cultural and linguistic compentency as the relevant issues should be addressed in the individual's assessment and ISP
• Eliminating the requirement for a specialized fall risk assessment as the relevant issues should be addressed in the individual's assessment and ISP
• Change the requirement for the review of the of the ISP "at least every three months" to base the review dates on the date of implementation of the plan
• Require that a Transfer Summary be prepared only if the entire record does not accompany the individual to the new service/location

I would like to support language regarding educational requirements for supervision to read:

Possession of a bachelor's degree in a behavioral science or human services field w/ 2 years of professional experience working with person with intellectual disabilities or long-term mental illness; OR any equivalent combination of experience and training which provide the required knowledge, skill and abilities.

Instead of the strict requirement of a bachelors degree.

Proposed revision to include equivalency language:

Revisions to licensure rules and regulations that may adversely directly impact service delivery to at-risk youth include the following:

1. 12VAC35-105-20, Definitions, “Qualified Mental Health Professional (QMHP)”.  The revision includes only the QMHP working in a PACT or ICT.  The definition is not clear as to whether QMHPs can work in intensive in-home and mental health community support services.  The revision should also include, at a minimum, the QMHP working in intensive in-home and mental health community support services.
2. 12VAC35-105-590. Supervision guidelines (Provider staffing plan C9) for Intensive-In Home Services are more stringent than those required for comparable state reimbursed services. We recommend that C9 be REPEALED. Providers should be charged with the responsibility of ensuring supervision is appropriate to the services provided.  Supervision and employee licensing costs are significant expenses for any home-based provider.  Micro-management in this area will drive related costs up even higher.  If the decision is to leave C9 as is, providers should be given clear-cut guidelines for ‘grandfathering,’ without penalty, current supervisors who do not meet the new criteria. 
3. In general, DBDHS and DMAS regulations do not match, continuing to leaving providers caught in the ‘gray areas.’ 
4. Licensing has issued “Guidelines” for intensive in-home providers that call for a restriction on the number of cases (no more than five) a worker may be assigned at one time.  Many providers use a team approach to intensive in-home counseling.  Restricting the number of cases would mean that providers would have to change their approach to one person per case so that employees who are considered full-time are not penalized for using the team approach.  In other words, currently, a staff member might work on eight cases with a team member and work three to five hours per case per week; this would bring their total hours to approximately 24 to 40 hours per week.  An employee working five FAPT funded cases would only be able to average approximately 30 hours per week maximum under the new guidelines.  Full time employees generally work from 35 to 37.5 hours per week in the in-home profession.  Most providers have a cap on the number of hours their employees are allowed to work due to the high rate of burn-out in the profession.  Providers should be held responsible to ensure that employees are not overloaded with cases so that the consumers receive the highest quality of care.
5. Providers recently received notice of a training in May from DBHDS on evidence based practices which is yet another cost to providers, in addition to the increased supervision costs, etc.  Members of VAFP are committed to the utilization of best practices to ensure quality services. 

Re-consider the requirement of a person to supervise direct care staff within the MR/ID field, by permitting several years of direct care experience and extensive ongoing trainings and development to be equivalent to the educational requirement.