We have the following concerns/comments on the proposed changes

1.The proposed definition of abuse is too vague and open to frequent misinterpretation. It is not possible to accurately predict whether an action "might cause psychological harm" now or in the future.

2.We have previously shared our concerns about sexual assault being classified as a Level III serious incident. We agree that if a sexual assault occurs on premises or during the provision of services, it should be reported but requiring reporting of sexual assault to DBHDS disrespects the preference of the individual and may inhibit reporting and treatment.

3.We also feel that while all deaths can be reported, expected deaths should not be classified as Level III serious incidents requiring root cause analysis. This encumbers a significant amount of staff time for an outcome that was expected and adds no value to the process.

4. While we support the requirement that case managers serving individuals with  developmental disability shall complete the DBHDS core competency-based curriculum within 30 days of hire no allowance is made for when the DBHDS training system is unavailable.