• P33, Section 106-250, A6 and 7, Results of reasonable efforts to secure job-related references; Reasonable verification of employment history.  What is the definition of reasonable – this is a prime example where different licensing specialists could have very different expectations for this.  Suggest requiring instead that it be documented if 3 references or most recent employment history cannot be obtained and other supporting documentation if the decision is  made to hire.
• P36, Section 106-300, B1 Within 7 business days following an employee or contractor’s start date, each employee or contractor responsible for supervision of individuals receiving services shall receive basic orientation and training regarding:… b) Cardiopulmonary resuscitation (CPR) and first aid training issued by the American Red Cross, the American Heart Association, or comparable authority in standard first aid and CPR. The training shall have a certification process which shall include a hands-on, in-person demonstration of CPR competency…. and c) medication administration including basic pharmacology and medication side effects. This is not a feasible time frame for programs that do not have an in-house training department and most do not.  What is the definition of “supervision of individuals receiving services” – very open to different interpretations. For example would this include outpatient therapists. It should be made clear that the medication administration requirement is not be required for programs that do not administer medications. 

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