CAPA Compilation of Comments â DRAFT on ... - IHSS Coalition

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--Proposed 30-776.422. Change “County shall have the discretion” to “County shall.” Providers should not be penalized for administrative errors or delays. Also, add an additional (c) for other good cause at counties’ discretion. <strong>DRAFT</strong> REGULATIONS FOR PROVIDER ENROLLMENT REQUIREMENTS: PG 2-3. 1. (.3, .42 and .42) Consider using 3 calendar months verbiage instead <strong>of</strong> 90 days to calculate the exact # <strong>of</strong> days. Otherwise, the example given on page 3 is incorrect. 90 days would be retro pay from Sept 24, not Sept 22 (potential <strong>of</strong> two work days not getting paid); the period that the individual would not be eligible to receive payment from the IHSS program would be from August 12, 2012 through September 23rd (not Sept 21). 2. (.51) Consider adding SOC 426 after provider enrollment form the first time mentioned. PG 4. (.512) Consider changing "individual" to "applicant provider" for consistency. PG 5. 1. (.514a) Consider removing the word "positive". It does not add value or meaning to the sentence. Consider rewording sentence to: "An unexpired ID document issued by a state or federal government agency, including a photograph (or physical description) and/or signature. 2. (.514b2) Consider requesting the right to work docs WITH the social security card (when it includes the need for DHS auth), otherwise, the burden is on consumers and/or the DO staff to verify this info. 3. (.514b2A) Add an "i" to information. 4. (.515a) Confirm that our (DPSS) record retention matches this one year period. 5. Clarification needed: who will retain these docs PA, DO, IHSS recipient Specify. If PA/DO, confirm that our DPSS record retention matches this time-frame. PG 6. 1. (.53) Consider adding SOC 846 after the provider enrollment agreement is first mentioned. 2. (.531b) Remove "and fingerprinting, when implemented" since according to SB 930, the IHSS recipient fingerprinting has been eliminated. 3. (.532) Confirm that our DPSS record retention matches this "indefinitely" retention period. HR regs for Riverside County is currently set at 75 years. 4. (.541a) add a colon after crimes instead <strong>of</strong> a period since a list proceeds.
5. (.541a2A) Consider removing the "HANDBOOK BEGINS HERE" since the next section is part <strong>of</strong> the existing section. PG 7. 1. (.541a2A) Consider removing "HANDBOOK ENDS HERE" (same reason as above). 2. (.541b) Specify "date" to date "prints submitted" OR date "results received" 3. (.541c) Add comma after facility. 4. (.562a) Specify how the verification will be done: as evident in authoritative docs from court, district attorney's <strong>of</strong>fice, etc. How is this going to be done The ENRL fingerprint field is for "results received" and NOT for "clearance". Also, one cannot look solely at "CORI Date" fields because PRIOR to Feb 2011, "not cleared" determination were not populated to the ENRL screens. PG 8. 1. (.563) Specify if originating county is same as "DOJ county" on ENRL screen (consistency). PG 12. 1. (.683) Consider removing "HANDBOOK ENDS HERE" since the following section (d) is part <strong>of</strong> the existing section. 2. (.733b) Is something missing after "and" PG 13. 1. (.842) Confirm with our existing record retention matches this period. 2. (.921b) Add "a" within is disqualifying. PG 14. 1. (.922) Specify for how long this info will be retained. 2. (.922c) Add a period at end <strong>of</strong> sentence instead <strong>of</strong> a semicolon. Page 1/Section .11 • Question or Concern–I understand the definition but this cause lots <strong>of</strong> problems thorough out the rest <strong>of</strong> the document when is says the “county” will, in some counties the Public Authority does those functions so the document would have to be amended to say county/county PA • Suggestion – modify the definition Page 2/Section .42
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CAPA Compilation of Comments â DRAFT on ... - IHSS Coalition

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CAPA Compilation of Comments â DRAFT on ... - IHSS Coalition