General Comment:
Final Regulations are effective 8/1/20 and will begin to be enforced 11/1/20. However, adequate training has not been provided to assist providers with becoming compliant with these regulations. It is reasonable to expect that training would be provided in a timely manner to support providers in gaining proficiency, allow for development of a meaningful QI program plan, training staff, etc. well before the enforcement date of regulations and certainly at a minimum prior to the regulations becoming effective.
Hope House Foundation agrees with Andie Plumley's comment:
Public comment on statewide performance measures should be included if providers are required to report on them.
The cost of creating, implementing, and reviewing data collection systems to meet this requirement must be taken into consideration. Low reimbursement rates for waiver services are already creating a staffing crisis, additional administrative costs only add to this critical shortage by absorbing funds that could go towards increasing DSP wages and benefits.