And Yet One More DOJ Related “Review”

September 24, 2020

We were tipped off today that DBHDS is making phone calls to provider locations (sponsored residential homes, group homes, and the like) to give notice that those locations will be called by one of two reviewers contracted by the Independent Reviewer (specifically noted is that the calls will come from area code 413) to schedule an interview with a staff member who has direct knowledge of the implementation of the behavior plan for a named individual.  Remarkably part of the script being read indicates that “it will not be necessary, or helpful, to have higher ups from any service provider who does not work with the individual in the home daily to be interviewed.”  


There are so many things wrong with this approach, it is hard to articulate:



  • DSPs are generally expected to decline to discuss any individual in the home with any unknown person on the phone as it is a violation of the rules of confidentiality

  • It is highly unlikely that the individual who takes the “heads up” call will clearly convey the substance of the call and very unlikely that they will be the same person to take the subsequent call from the reviewer, and

  • Whoever is selected to be “interviewed” which is expected to take an hour, will need to be out of the residence, not responsible for providing supports, in the corporate office or other location where their conversation can be confidential, and be paid for time and travel.  All of these arrangements will need to be made with a “higher up.”


In other words – calling a residential program or a sponsored home may the least effective way to communicate this kind of request.  


Another interview to be scheduled – perhaps they can get in the queue behind the QSR, the HCBS pilot, a required site visit and any necessary response to a COVID outbreak!