,f : Amanda M The Arc. Mercer County

Transcription

1 Kroh, Karen 77- i (0 LçbLSC_() From: Amanda M. Nicol <anicol@mercerarc.org> Sent: Friday, December 16, :27 PM To: Mochon, Julie; Kroh, Karen Cc: Diane M. ORourke; Shin A. Meyers; epic@wpa.net Subject: Regulation Comments: 2380, 2390, 6100, 6400, 6500 Attachments: 2380 FORM.docx; 2390 FORM.docx; 6100 FORM.docx; 6400 FORM.docx; 6500 FORM.docx Dear Ms. Mochon and Ms. Kroh, Please find attached five documents, one for each set of regulations (2380, 2390, 6100, 6400, 6500), that include comments from MCAR. Thank you for the opportunity to provide feedback during this critical process. Happy Holidays and Happy New Year, Amanda Nicol,f : Amanda M The Arc. Mercer County f,r4h ariddi T,,cabht Che Opracu-g OFe N Herru Kemi9ePAIi gSOx21 Ffl4-9BI18fl yvjocarçcw ri ) 1

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3 Definitions Application laws and regulations Program specialist Staffing Annual training plan Orientation program Chapter 2380 Nicol-Comments Template

4 I PAR Comments on Chapter 2380 Adult Training Facilities Page 2 of Annual training Oppose Overall of the The Rights Team should meet every 3 months on confirmed violations and a term should be set for the violation. Replacing the Restrictive Procedure Review Committee and your decision not permitting agencies to have any restrictive programming waiving the individual s rights is putting the individual and other individuals health and safety at risk (Reserved) Content of Records Assessment

5 cc: Nancy Thaler, Deputy Secretary, Department of Human Services, ODP Page3of3 PAR Comments on Chapter 2380 Training Facilities Adult

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7 Application laws and regulations Staffing Orientation program Program specialist Definitions Chapter 2390 Nicol-Comments Annual training

8 PAR Comments on Chapter 2390 Vocational Facilities Page2of Content of records Assessment Use of a positive intervention thru Opposed The Rights Team should meet every 3 months on confirmed violations and a term shou d be set for the violation PSP Prohibition of restraints

9 Page 3 of Permitted interventions Access to or the use of an individual s personal property Rights team Self-administration Medication administration PAR Comments on Chapter 2390 Vocational Facilities

10 PAR Comments on Chapter 2390 Vocational Facilities Page 4 of Storage and disposal of medications Labeling of medications Prescription medications Medication record Medication errors Adverse reaction

11 PAR Comments on Chapter 2390 Vocational Facilities Page 5 of Medication administration training cc: Nancy Thaler, Deputy Secretary, Department of Human Services, ODP

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13 Purpose (a) Applicability Definitions Appeals Monitoring compliance Regulatory waiver t Chapter 6100 Nicol-Comments Template

14 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability orautism Page 2 of Innovation project Quality management Protective services Criminal history checks Funding, hiring, retention and utilization

15 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 3 of Child abuse history certification Communication Grievances (f) Opposed It is the Incident Management Committee s responsibility to review incidents and determine what incidents are confirmed and which are not confirmed.the Rights Team should meet once every 3 months for confirmed incidents and a term should be added. Once an incident has been corrected with a proven track record, the Rights Team should no longer be required to meet every 3 months Conflict of interest

16 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 4 of Recordkeeping Reserved capacity (c)(1) HCBS provider requirements Opposed Further explanation is needed on this as it is not clear HCBS documentation Submission of HCBS qualification documentation

17 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 5 of Provision, update and verification of information Ongoing HCBS provider qualifications Delivery of HCBS Annual training plan

18 V V Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 6 of thru Orientation program Opposed If funding is not available a provider should not be obligated to provide orientation training to consultants and vendors if nondirect billing isn t permitted Annual training Natural supports Exercise of rights Rights of the individual Additional rights of the individual in a residential facility

19 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 7of Negotiation of choices Informing of rights Role of family and friends Development of the PSP The PSP process

20 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability orautism Page 8 of Content of the PSP Implementation of the PSP Support coordination and TSM Documentation of support delivery Access to the community

21 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 9 of Employment Education Individual choice Transition to a new provider Reasons for a transfer or a change in a provider Written notice

22 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 10 of Continuation of support Transition planning r Transfer of records Use of a positive intervention Support. Good change of title from Safe Behavior Management PSP

23 Change title to Prohibition of certain types of restraints. Title can be misleading to appear that no restraints are allowed, ever Opposed agreement. The tenant would be responsible for any damages made by them This is in conflict with a typical community lease beyond normal wear and tear Prohibition of restraints Permitted interventions (b) Access to or the use of an individual s personal property Types of incidents and timelines for reporting Incident investigation Page 11 of28 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism

24 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 12 of Individual needs Final incident report Incident analysis Request for and approval of changes Physical accessibility

25 Opposed access cards. Funding must be available for the replacement of keeys or (a) Access to the bedroom and the home Lease or ownership Integration Facility characteristics relating to size of facility Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 13 of 28

26 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 14 of (b) Facility characteristics relating to location of facility Opposed Individuals should have the right to pick and choose what apartment complex that they want to live in regardless of who lives there. As a provider we would not have the right to ask if other tenants have a disability Self-administration (b) Medication administration ADDITION Add rectal medications to medication administration Storage and disposal of medications Labeling of medications Prescription medications

27 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 15of Medication records Medical errors Adverse reaction Medication administration training Exception for family members

28 I Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 16of Department rates and classifications Payment Title of a residential building Provider billing Audits

29 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 17of Bidding Loss or damage to property Fee schedule rates Cost-based rate Assignment of rate Submission of cost report

30 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page l8of Cost report Rate setting Cost-based rates for residential habilitation Allowable costs Donations

31 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 19 of Management fees Consultants Governing board Compensation Training

32 V Comments on Chapter 6100 Support for Individuals with an Intellectual Disability orautism Page 20 of Staff recruitment Travel Supplies Rental equipment and furnishing Communication V Disóussion: Rental of administrative space

33 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 21 of Occupancy expenses for administrative buildings Fixed assets Motor vehicles Fixed assets of administrative buildings Residential habilitation vacancy

34 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 22 of Indirect costs Moving expenses Interest expense Insurance Other allowable costs.

35 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 23 of Start-up cost Reporting of start-up cost Cap on start-up cost Room and board applicability Support to the individual No delegation permitted

36 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 24 of Actual provider room and board cost Benefits Room and board rate Documentation Completing and signing the room and board residency agreement

37 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 25 of Modifications to the room and board residency agreement Copy of room and board residency agreement Respite care Opposed The rates need to be sufficient to cover the increase in the food budget if room and board is not a viable revenue source from respite services Hospitalization Exception

38 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 26 of Delay in an individual s income Fee for the ineligible portion of residential habilitation Sanctions Array of sanctions If these are not licensing regulations, the language should not be so focused on corrective action. Change title to Remediation Consideration as to type of sanction utilized

39 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 27 of Additional conditions and sanctions Adult autism waiver (d) Agency with choice Opposed This is in conflict with the Managing Employers contract. If they can t meet the responsibilities in the contract, then a new Managing Employer or Supports Broker should be hired Support coordination, targeted support management and base-funded support coordination Organized health care delivery system Discuss i o ri:

40 Comments on Chapter 6100 Support for Individuals with an Intellectual Disability or Autism Page 28 of Base-funded support Vendor goods and services Opposed The Vendor Fiscal Provider does not have the ability to assure that the vendor has met all the requirements. That should lie with the Supports Coordinator if a Vendor Fiscal Provider is only responsible for writing check cc: Nancy Thaler, Deputy Secretary, Department of Human Services, ODP

41 V V Nicol-Comments Chapter 6500 Family Living Life Sharing Homes Introduction Purpose Applicability Definitions Responsibility for compliance V Self-assessment of homes

42 PAR Comments on Chapter 6500 Community Homes for Individuals with an Intellectual Disability or Autism Page 2 of Applicable laws and regulations Effective date of staff qualifications Chief executive officer Supervision [Training.] CPR, first aid and Heimlich maneuver training

43 V V PAR Comments on Chapter 6500 Community Homes for Individuals with an Intellectual Disability or Autism Page 3 of Annual training Training records Indoor temperature Furniture

44 PAR Comments on Chapter 6500 Community Homes for Individuals with an Intellectual Disability or Autism Page 4 of (B)(2) AND Opposed Life Sharing families should not be mandated to complete and pass the Department s approved medication administration course. Over regulating Life Sharing families will deter families away and puts more barriers to achieving an Everyday Life for individuals Medication administration training Assessment Day services Recreational and social activities

45 V PAR Comments on Chapter 6500 Community Homes for Individuals with an Intellectual Disability or Autism Page5of (Reserved) Content of records Record location Access cc: Nancy Thaler, Deputy Secretary, Department of Human Services, ODP

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