This 'guidance' document contains more threatening language of punitive action against providers than actual guidance to ensure quality supports.  By not allowing communication between the licensing agent or human rights advocate and provider to count as a timely report it diminishes the relationship between provider and their DBHDS ‘partners.’   Not all “serious incidents” are black and white and often a provider will reach out to their licensing agent or advocate to ensure accuracy.  This provides an opportunity to foster communication and build trust between offices and providers.  The timeframes for reporting are ridiculous… they take the focus away from providing supports to the individual (as well as family and staff who may be working through a trauma) and places it on reporting to a system.  They force the provider to prioritize haste over accuracy. The ‘guidance’ in this document illustrates an adversarial position taken by DBHDS as opposed to supporting and fostering positive relationships with providers to ensure the best supports for the community we are all supposed to be serving.