A. “Individual risk screening”: the guidance is unclear/vague as to the components of the screening; as a risk manager, completion of ‘screenings’ seems beyond the scope of the role, as a the risk manager should be an evaluator of assessments/screenings such as these that are completed by the direct service provider in an attempt to provide feedback regarding adequacy and the provider’s compliance with the tool, areas for improvement, etc.

D. “Uniform Risks and Triggers”: requirement to adhere to an undefined parameter is unrealistic and should be removed or delayed in implementation until the parameter is outlined and disseminated