Virginia Regulatory Town Hall
Department of Behavioral Health and Developmental Services
State Board of Behavioral Health and Developmental Services
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5/3/18  10:26 am
Commenter: Adam Page

Draft ISP Guidance

I have had the opportunity to review the "Draft ISP Guidance" being submitted for what I'm assuming is implementation in the next few months. I want to start by saying that I appreciate the hard work folks have put into this document and I understand that in order to comply with the Settlement Agreement, change is inevitable. I'm sure this is as frustrating for folks in the department as it is for the people on the front lines trying to balance the provision of quality care with the ever growing mountain of required documentation.

For those of us who have been in the field and system for some time, this new guidance is looks a whole lot like a return to the original Outcome development format that we were all taught nearly a decade ago. It's maddening to think that the past few years in terms of time, expenses, and hard work have essentially been for nothing. It's also maddening to see that we are seemingly returning to the old plus and minus data driven documentation that pervaded this field in the sheltered workshops and day centers of the 1980's and 90's. Unfortunately, if this new process is implemented as is, providers will be asked to yet again increase the amount of daily documentation that is required. They will be tasked with figuring out how to incorporate data collection forms into the EHR's and front line staff will have a new documentation requirement to add to the already ridiculous amount of work they already do each day where they balance caring for the least among us with somehow being responsble for clinical documentation requirements that RN's don't even utilize.

It's important to note that over the past decade, documentation in terms of sheer volume has increased radically. Part I-IV are now routinely over 30 pages. Part V's now are routinely 15-20 pages. Then you have an enourmous volume of support note documentation each month. Adding new forms to track data that should already be identified in the support note is redundant and completely unecessary. In my opinion, adding additional documentation is simply not conducive to allowing front line staff to devote the time they need to skill building, routine care, and health and safety, etc. 

Going back to the old way by adding prepositional phrases to outcomes is fine. The logic makes sense. In fact, I like the logic behind requiring more specificity with outcomes and adding measurement phrases to both outcomes and support activities. I think it actually helps staff identify what they should do and then write better notes. But creating new forms and more documentation in a system that is inarguably over saturated with documentation makes zero sense.  There is simply no other Medicaid service that requires the amount of documentation as ID/DD Waiver services. Quite frankly, it's ludicrous considering that all across the heatlh care industry and Medicaid service spectrum, service plans can be accomplished in 1-5 pages. Somehow, we've established a system where an individual who has 3-4 Waiver services can legitimately have a 100+ page support plan (counting Part 1-4 and all Part V's). How is 100+ page support plan efficient and effective with helping people live the lives they want? Let's stop losing quality staff at unprecedented rates because of the documentation requirements and let's figure out a more common sense way to document progress.

CommentID: 65279