Regarding the guidance regarding C.1. be reviewed and updated annually. The guidance section states that it should update the QI plan based on the issuance of CAPs.  Due to the significant number of corrective action citations now being issued this may become an onerous activity of constant revision, especially for large organization that are providing a wide range of services.  The department should clearly indicate that having a goal that states that the agency will implement CAPs, monitor their success, and if not successful identify different strategies without re-writing the QI plan is sufficient for meeting this expectation.

RE: Item 3 Include and report on statewide performance measures.  I believe that most organizations are attempting to do this outside of the QI plan.  It would be a more meaningful activity for agencies if there was a way to clearly see how the state is calculating measures so we could duplicate their results.  This would give us clarity as to what the issues are and give us greater opportunity to improve our results.