Several concerns over the proposed changes. 

1.  Accountability fro unsigned or delayed signing of plans of care.  This would impact the Self Audit and its effect on Cost Reimbursement.   I don't think you realize how difficult it is to get paperwork back in a timely manner from physicians if at all. 

2. Physicians may charge for signatures/paperwork.  Who would be responsible for these costs, division or parents?  

3.  If parents have to pay for paperwork, they may potentially decline or revoke consent and thus impact our cost reimbursement through our self audit/BCR. 

4.  With the proposed changes, the increased documentation requirements, increased work for staff to insure compliance and still with the potential loss of reimbursable funds for division we may not be able to bill for personal care and nursing or hire additional staff.  

5.  Personal care services do not require orders from a physician.  It does fall within the scope of nursing practice. 

My Biggest Concern is that I attended the proposed manual revision meetings and do not recall this coming up at the meeting.