The RAT, the VIC and the QSR!

July 13, 2020

The very burdensome licensing reviews were only the beginning – last week we talked about the RAT (Risk Awareness Tool) which may have been developed with good intentions, but sets such a low bar that 99% of individuals who qualify for the DD Waivers will show risk in several of the categories!  If a risk indicator is listed, there will be a plan, eg., a plan to reduce “seizure” will be expected for anyone diagnosed on the autism spectrum, a plan to reduce the risk of falls for anyone with four medications (including PRN and OTC) daily, or a plan to reduce the risk of bowel obstruction if there is a prescribed laxative. The VIC (Virginia Informed Choice) was just posted by DMAS for comment.  It will be completed annually, and besides adding time to an already cumbersome process, it pushes individuals and/or families to be specific about their selection or denial of a service provider.  At best it gives the individual a real sense of control, at worst it makes the decisions harder and more intimidating. And last, but certainly not least, the QSR!  The first thing you will note is that they are already 10 days behind the timeline specified in their own document giving providers/CSBs only two days to respond to the first request for data!  This does not bode well for their ability to implement and complete the comprehensive record and site reviews of all services by all providers (DD) twice between now and 15 February of 2021.  Take comfort in that one of their targeted objectives is to provide DBHDS with recommendations for streamlining and reducing administrative burden on providers!  There are a number of issues that will need to be resolved –
  • how will they accomplish “direct observation of the individual at each of their service sites” in the midst of a public health emergency when day services are not being provided and residential services are still maintaining self isolation precautions,
  • how will they accomplish interviews virtually, (except by voice only) without the availability of the appropriate technology, and
  • how will they assess any compliance with the intent of the community integration components of the HCBS Settings Rule when community integration in strongly discouraged for obvious reasons.
The volume of paper that will need to be copied, scanned and sent by secure email will make the recent requests by the Office of Licensing seem very small!  They do, however, seem to be asking mostly the same questions!  Validation of the work done by DBHDS Office of Licensing has just become the provider’s problem!