• Please provide clarification regarding two year time frame for tracking citations. When does the two years start –effective date of guidance being approved? Is this a rolling two years, fiscal year, calendar year, etc.?
• If the expectation is for providers to have all reports entered on CHRIS within 24 hours 100% of the time with little allowance for extenuating circumstances per this guidance, then a representative from DBHDS should be available 24/7 to read these reports and be available via phone call if needed to take a report. Access to Internet to complete CHRIS or email IMU is not always available particularly for rural communities.
• Please consider an agency’s size when having progressive citations due to late reporting. For larger agencies, a percentage may be a more fair, accurate way of identifying systemic issues with late reporting. It seems that it would be more beneficial to both DBHDS, community providers, and the individuals served to truly focus on systemic issues based on patterns and trends of non-compliance.
• The requirement for updates to CHRIS to be entered within 48 hours is very strict. Often times these updates are dependent on obtaining information from external sources (hospital, psychiatric facilities, etc.) which is outside of the provider’s control.
• In regards to progressive citations, please detail the steps that providers can take if issued provisional license to come back in to good standing.
• There are significant concerns that these additional guidance documents are essentially being treated as another set of regulations to be followed. It seems that technical assistance has been replaced with citations.
• Overall, there are concerns regarding the punitive language of the guidance which leaves little allowance for human error and does not foster a collaborative relationship between DBHDS and community providers in order to best meet the needs of the individuals we serve. It is also extremely discouraging to providers to have the guidance document already be in effect prior to the public comment. It is unclear how this guidance ultimately improves the quality of services being provided as it places additional administrative burdens and resulting financial costs on CSBs.