re: quarterly reviews by CM's - There needs to be consistancy with this process in order to allow the CM's opportunity to review providers quarterlies. Allowing CM's till the end of the month, or 30 days if the due date is toward the end of the month, to complete the quarterly takes into account the late quarterlies from providers. 15 days from the due date of the quarterly is not enough time to complete documentation.

There needs to be consistency between 90 day visit, 3 month visit and quarterly visit or clarification. Producing more documentation does not make sense when it is redundant. 

12VAC30-50-490 E.6 There are different qualifications for DDCM and IDCM. This needs to be consistent. There is not a difference between DDCM and IDCM - Individuals diagnosed with disabilities are as varied as those without that diagnosis and the supports needed also are varied. Continuing to separate these services is not advantageous to the population we serve.  It would make sense for all case management to be considered and named Developmental Services Case Management/Support Coordination with the same rights. rules and regulations for all individuals under that umbrella. 

re: a minimum of 8 hours of training for the CM/SC's requires clarification in order to explain who is providing the training and what constitutes and qualifies for this requirement. Do the initial new CM modules cover this for new CM's/SC's? or the Housing Modules? or the Support Coordinator Regional meetings?

Thank you, 

Kathy O'Keefe  - Eastern Shore Community Services Board, Director of Developmental Services