Page 9 of the General Chapter has conflicting information with page 16 of the Home/Non-Center Based Chapter regarding the timeframes in developing the initial ISP.  General Chapter, page 9 states that the initial ISP means a written plan developed and implemented within 24 hours of admission.  Page 16 of  the Home/Non-Center Based Chapter states to develop and implement the initial ISP 24 hours after admission. Please confirm that the initial ISP can be developed anytime after the assessment and up to 24 hours after the admission date (start date of services).

Page 16  The level 3 incident type of permanent physical or psychological impairment was removed per DBHDS training we received.  This chapter still has this level 3 incident type.  Please confirm if this is still a level 3 incident. 

Page 34  An employee can work direct care without receipt of the background and registry checks if they are working under the direct supervision of another employee who has had these checks completed.  Please confirm that this change will apply to residential services.  For residential, currently we must receive results prior to having the staff working in the home. 

Page 51  Please clarify definition of a licensing complaint (related to complaint handling process) as this is different from the human rights complaint handling process.