Managing Competency

April 05, 2021

There were many good ideas and concerns shared during the review of the DD Waiver Final regulations last Friday and we will follow-up on all over the course of the next week or two.  The one that has and will continue to cause the greatest amount of discussion and which will cost the provider community the most amount of administrative time and attention for the least amount of benefit to the individuals we support (or the staff who support them) are the embellished requirements for the Competencies Checklists.  A few things to keep in mind:

• The checklists refer to competency, but competency is not sufficient!
• The rather specific added requirements [12VAC30-122-180 B. 5.] for monitoring and completing the remediation of a lack of proficiency (or deficiency) leave providers to conclude that the “proficiency” required for everyone in order to minimally perform their job functions is the standard for “adequate.”  So the measure of “proficiency” must be recognized as “adequate.” 
• Except in very small programs with a single location, it will be very difficult to use the “form” as a working document; the form can not be both retained in the personnel file and be available for the Supervisor to use for documentation on an ongoing basis.  Clearly some other tool will be required to communicate and document ongoing progress toward or regression from proficiency (and remediation if required).  This is where the provider can attempt to link their performance management system to the “Competency” tool. 

There is the added component in these regulations [12VAC30-122-180 B. 4.] that staff must be “competent” in health and safety skill prior to working alone.  In other words the skill can be performed, but has not been observed consistently over time.  These items (listed in Competency 3) are, to be fair, the types of skill that staff would require prior to being “on shift.” 

They are also skills which may not be applicable, for example, there may be no need to learn about special food preparation skills if none are required for the individuals supported.  And, as training in the administration of medication may not occur during intial inservice, providers already have plans in place to ensure  that properly trained staff are available as needed.  Proficiency or adequate performance is the expected baseline for this particular task!

One last note:

• The form (DMAS P241a) posted on the DMAS website is dated 11/28/2016,
• The form (DMAS P241a) linked to the regulations is dated 06/10/2016, and
• The form (DMAS P241a) specific to the content of the regulations (re Competency 3) was posted as a Guidance Document  (DBHDS DD2) in March 2020!