In the notice, it states that these regulations would apply to providers "who accept Title IV-E funding to meet the standards as QRTP's.  Providers who do not accept Title IV-E funding shall not be affected by this action."  Understanding this, the regulations should only apply to group homes, as no PRTF providers are able to accept IV-E funding, regardless of the facilities status as a QRTP.  I would recommend clarifying language be added to the regulations to show that PRTF's who are QRTP's do not fall under this language if, indeed, "providers who do not accept Title IV-E funding (are not) affected by this action."

1. I am not clear on the expectations for nursing or licensed staff.  The document referred to subsection A. “have registered licensed nursing staff and licensed clinical staff who are available 24 hours a day and seven days a week”    Will on call suffice? Do they need to be on campus?  A clearer statement of what this means for providers would be helpful.
2. Section D-E are difficult for providers to do especially in foster care cases.  What is the actual expectation of this?  Just try to make contact?  Show something else?  It seems like more paperwork to do rather than anything else.
3. Section F—what does ensure mean?  This makes it sound like a residential needs to follow these cases, check in and provide some level of case management.  Where will funding come for this?  It seems manifestly unfair to ask residential providers to do this when there are community based services such as ICC that are better equipped to handle this aspect of care.  It increases liability for the provider as well if the family is still considered a “case” that is being followed.
4. Please add clarity so providers know exactly what to expect within the regulations as we will be held to this and the required documentation status.