December 14, 2016
In mid-November we suggested that you delay any real effort to roll out the competencies checklist, integrate it with all of your existing systems for maintaining the quality of staff performance or develop protocils and train supervisors in it’s use as there were going to be changes. The changes have been widely distributed.
We are concerned that the revised format
will put providers at considerable risk during an audit as the Orientation Manual Test (which must originally be completed before staff are qualified to provide billable service) must be repeated if staff are not determined to be “proficient” on any individual item. How this might be interpreted during audit has not been determined, but is a significant concern.
The second concern is less of an audit risk, but nonetheless an issue. The regulations require “competency;” the format presented in November defines “competency” as “individual demonstrates the skill or actions, but not on a routine basis as appropriate to the skill or action; low level of supervision needed.” This differs from “proficiency” in the frequency that staff demonstrate the skill or action (on a routine basis) and that only “minimal” supervision is needed. The current interpretation of the requirement is that “competency” is not sufficient and that all items must be rated proficient in order to rank each of the three “competencies” proficient.
As we know, any system that ranks all employees “excellent” deflates the significance of that rating and leaves no room for actually recognizing outstanding performance. This system makes “proficiency” the adequate level of performance and each of us can use our existing systems to recognize our outstanding performers!