1. 3. Methods to assist individuals who are not admitted to identify other appropriate services.

Comment: Please remove or clarify. This is the responsibility of Support Coordination not private providers.

2. A. In the event that an individual has been placed on a waitlist prior to receiving services a secondary screening shall be performed prior to admission to the service. The provider shall document:

Comment: According to 12VAC30-122-120, providers cannot have a waitlist as they are expected to be able to serve within 30 calendar days of the referral. Is this regulation contradictory or are we misinterpreting 12VAC30-122-120?

3. 2. After each training, providers shall test the employee’s or contractor’s knowledge, competency or both, and retain documentation of the test of the employee’s or contractor’s knowledge, competency or both within the employee or contractor’s personnel file.

Comment: this places an undue burden on the provider to show competency and is a duplication of effort. This will cause a significant amount of time to create ISP specific tests. We already document our training on ISP’s and ensure understanding of the needs of the person.

4. Describe follow-up care that is needed or note which objective within the ISP will be focused on the next time the individual receives services; and

Comment: please explain the purpose of this regulation.

5. 12VAC35-108-130. Staffing

Comment: Non-center-based day: please reconsider the 1:1 and 1:3 ratios for Coaching and Engagement. Some groups may be larger based on interests and needs.  These services have been very challenging to operate with the low ratios. Allow ratio’s to be defined by needs rather than fixed.