106-480 Policies..

18. A traffic pattern for center-based services that establishes a safe process for drop-off and pick-up of individuals who are transported by motor vehicle with site-specific application;

Feedback: The provider may or may not have authority to determine traffic patterns at particular sites, nor can the provider regulate the practices of motor vehicles that may be dropping off and picking up individuals or other traffic in the immediate area. This regulation is an unfair and unrealistic burden on providers.

106-490 emergency medical information

A. The provider shall maintain the following emergency medical information on a completed face sheet and updated for each individual when changes occur:

Feedback: The provider can only know when changes occur in emergency medical information when informed accurately by the individual.  Consider modifying language to reflect that reality by adding”…or when informed by the individual or guardian or at least quarterly.”

106-550 Privacy

Each provider shall have written policies and procedures regarding privacy, social media, photography, and audio or audio-video recordings of individuals that shall ensure and provide:

5. A prohibition on staff visitors.

Feedback: What does “a prohibition on staff visitors” mean? There are many times when the site of service delivery for individuals is also a site at which meetings convene or other members of the public might be present.

106-690 Building & grounds

A. Any service location’s grounds shall be safe, properly maintained, and free of clutter and rubbish. The grounds include, but are not limited to, all areas where individuals, staff, and visitors may reasonably be expected to have access, including roads, pavements, parking lots, open areas, stairways, railings, and potentially hazardous or dangerous areas.

B. The interior and exterior of all buildings shall be safe, properly maintained, clean, and in good working order. This includes, but is not limited to, required locks, mechanical devices, indoor and outdoor equipment, and furnishings.

C. Outdoor recreation space shall be available and appropriately equipped for the individual’s' use.

Feedback: A: In leased space, the provider may have limited authority over the condition of these areas.  A caveat should allow for evidence that the provider has attempted to identify and remediate any problem areas that the provider does not directly control.

C: What does this mean? Some buildings do not have grounds for recreational space. Nor would it be compatible with the nature of many services to provide recreational space.