The comments and concerns posted by Mary Ann Bergeron, Executive Director of the VACSB incorporate the concerns of Prince William CSB.  Those that are of particular importance are:

• Restricting qualifications of Behavioral Health staff.  We readily acknowledge the need for competency, we also know, that experience in the profession with good supervision results in highly skilled and effective staff.  Changes in qualification must be balanced between the competency required for quality services with specific client groups and the decreasing pool of new people entering our profession.   “Grandfather” staff who meet current DMAS qualifications is crucial.
• Documentation – references should be specific that payment retraction will result after failure to document substantial recording requirements and/or clear patterns of failure to document.  Incidental failures are not uncommon.
• For people with serious mental illness as well as some ID consumers who require assistance with daily living often include budgeting, shopping, travel training, etc. which need inclusion when “activities of daily living” is used.