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    • What We Want --- SAMHSA Grant Opportunities Due Jan. 22, 2019
    • Anti-Social Personality Disorder >
      • DECONSTRUCTING ANTISOCIAL PERSONALITY DISORDER AND PSYCHOPATHY: A GUIDELINES-BASED APPROACH TO PREJUDICIAL PSYCHIATRIC LABELS [Hofstra Law Review 2013]
      • Personality Disorders -- Unscientific & Vague -- Must Be Reformed
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      • Job Accommodation Network on Executive Functioning Deficits
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      • OIG: STATE STANDARDS FOR ACCESS TO CARE IN MEDICAID MANAGED CARE (Sept. 2014)
      • OIG: ACCESS TO CARE: PROVIDER AVAILABILITY IN MEDICAID MANAGED CARE (Dec. 2014)
      • GAO 15-710: MEDICARE ADVANTAGE: Actions Needed to Enhance CMS Oversight of Provider Network Adequacy (Aug. 2015)
      • CMS: Promoting Access in Medicaid and CHIP Managed Care: A Toolkit for Ensuring Provider Network Adequacy and Service Availability (April 2017)
    • Medicaid Mental Health & Substance Use Disorder Parity >
      • CMS Parity Compliance Toolkit Applying Mental Health and Substance Use Disorder Parity Requirements to Medicaid and Children’s Health Insurance Programs [Jan. 17, 2017]
      • Frequently Asked Questions: Mental Health and Substance Use Disorder Parity Final Rule for Medicaid and CHIP [CMS October 11, 2017]
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      • Statement of the Department of Justice on Enforcement of the Integration Mandate of Title II of the Americans with Disabilities Act and Olmstead v. L.C. (2011)
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      • Olmstead Nation ---State Pages: How Far to Comply with Olmstead?
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Staffing Page

An independent body

to regulate safe staffing ratios for systems that serve children, adults & elders with disabilities

We need an Independent Body to Recommend Staffing Ratios for:
  • CDHS facilities
  • Non-Profit & For Profit Facilities, &
  • K-12 Educational Institutions
serving Adults & Children with significant disabilities.

Such an independent body should also consider proposed alternatives to the recommended staffing ratios.

Additionally, entities should have some leeway for emergent circumstances and standard time frames to come into compliance.
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Staffing Ratios

Depending upon the State & the Facility or Environment -- Staffing Ratios are often attacked as "TOO RIGID."

We agree that Staffing Ratios need to have some FLEXIBILITY-- BUT we need to start with what is reasonably necessary to provide a SAFE ENVIRONMENT for individuals and staff as well as provide whatever services are legally required.

If providers or schools want to deviate from that -- then the burden should be on the provider or school to show they can do that in a safe way and still provide legally required services.

As far as we're concerned, providers [including State providers such as CDHS, non-profit and for-profit facilities, and schools] can get as CREATIVE & INNOVATIVE as they want to address these needs -- BUT we can't just keep PRETENDING that we're addressing them -- and somehow it is horribly impolite to expect these legal requirements to actually be met.



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National Consumer Voice for Quality Long Term Care
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         Look, we're never going to be able to fund everything we want.
          BUT this attitude in CO State Gov't that we're NOT going to fund what is legally required has to end.  That is really a form of CORRUPTION.
           The issue in most of these problems affecting people with significant disabilities is staffing.  We need something like the State Auditor's Office, that is independent, to deal with these issues on a routine basis.



​The Reason Why Grievance Procedures Often Don't Work
  
               Pretty much almost everyone would like to resolve issues @ the lowest possible level.

                But MOST problems have a SYSTEMIC COMPONENT.  It might be there just needs to be more TRAINING.  That's a FAVORITE because it's not really very expensive.

                 BUT the DEEP SYSTEMIC PROBLEMS affecting Systems serving Adults & Children with Disabilities, often involve STAFFING -- and that is much more expensive than training.

                  Further, the lower levels of a GRIEVANCE SCHEME generally have very limited ability to address NUMERICALLY INADEQUATE STAFFING.

                   Additionally, the folks @ the top of that GRIEVANCE TOTEM POLE may be facing considerable pressure to keep things within BUDGET.

                    Further, State Officials & various governmental subdivisions are also under considerable pressure TO DO MORE WITH LESS.

                   So we have A LOT of GRIEVANCES -- so there need to be OVERSIGHT AGENCIES -- generally, MULTIPLE OVERSIGHT AGENCIES.   Those agencies MIGHT get to NUMERICALLY INADEQUATE STAFFING -- but there are funding issues and political realities of the oversight agencies  to contend with here too.

                SO ADEQUATE STAFFING EVEN IF REQUIRED by LAW ---     is very, very difficult to obtain.

                 Well, there is the LAW -- right?  Yeah, but it is awfully expensive  -- and most of the people who need it enforced are poor and most middle class people can't even afford it.     

                   So from our vantage point -- that's why we have chronic staffing problems in multiple systems and institutions serving vulnerable adults and children with disabilities.  Further, those staffing problems are often most pronounced for Adults & Children with the HIGHEST NEEDS BECAUSE THEY ARE THE MOST EXPENSIVE.

                   We Need INDEPENDENT ROUTINE STAFFING AUDITS of all Systems and Providers, including Schools, that are providing services to Adults and Children with significant disabilities.

                    MORE THAN ANYTHING WE'VE GOT TO STOP PLAYING THESE EVIL GAMES.                  
                  
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Staffing:  SCHOOL Behavioral Health Edition

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SOURCE: BEHAVIORAL HEALTH COLORADO
DATA DESIGN: ERIC LUBBERS, THE COLORADO SUN
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No Colorado school districts meet federal safety standards for behavioral health staffing, investigation shows

​https://coloradosun.com/2019/04/12/colorado-school-districts-behavioral-health-staffing

Orchid:  Email

Crisis Services in Colorado, the US & Around the World

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  • Home
    • About Orchid >
      • Why Orchid?
      • ORCHID'S SYSTEMIC FOCUS & "ROOT CAUSE" ANALYSIS APPROACH TO PROBLEM SOLVING WITH A COMMITMENT TO CREATIVITY & INNOVATION
      • Disclaimers, Limitations and An Invitation
      • Orchid Board
      • Orchid Book Club
      • Conjecture, Science & Translational Research & Medicine
      • Orchid Themes & Symbols
      • The Tipping Point
      • Orchid's Website Advertising Policy
      • Statement for Potential Website Contributors
      • Contact
  • Blogs
    • Val's Blog
    • Val's Blog 2
    • ​TRANSLATIONAL/ ​TRANSITIONAL JUSTICE MONDAY
    • NEURO-DIVERSITY Wednesday
    • Olmstead Law & Order Thursday
    • Translational Medicine Friday
    • Translational Love, Relationships & Neuro-Diversity Saturday
  • Orchid's A-Z Index
    • Crisis Services in CO, the US & Around the World
    • Assertive Community Treatment & Flexible ACT Index
    • Housing & Homelessness Index
    • Criminal Justice
    • Innovation Index
    • For More: See the Main Orchid Index Page
  • US Federal
    • THE IMD RULE & ADMIN. ENFORCEMENT OF DISABILITY CIVIL RIGHTS LAWS
    • Medicaid & Supportive Housing & Housing-Related Services
    • CMS' FAILURE TO COVER HOUSING FOR LTC & THE IMD RULE: WHAT THEY HAVE IN COMMON IS DISCRIMINATION
    • National Take
  • Research & Translational Medicine
    • Immunology & Mental Health >
      • Alcoholism & the Immune System & Mental Health
      • Brain Injury, the Immune System & Mental Health
      • Celiac Disease & Sensitivities, the Immune System & Mental Illness
      • Mental Illness & The Immune System
      • Racial Discrimination & the Immune System & Mental Health
      • Trauma & the Immune System & Mental Health
      • ***Physical Health Issues, the Immune System & Mental Health Index
    • University of Chicago: Institute of Translational Medicine
  • Hot Topics
    • What We Want --- SAMHSA Grant Opportunities Due Jan. 22, 2019
    • Anti-Social Personality Disorder >
      • DECONSTRUCTING ANTISOCIAL PERSONALITY DISORDER AND PSYCHOPATHY: A GUIDELINES-BASED APPROACH TO PREJUDICIAL PSYCHIATRIC LABELS [Hofstra Law Review 2013]
      • Personality Disorders -- Unscientific & Vague -- Must Be Reformed
    • Executive Functioning & "Prison Brain" >
      • Job Accommodation Network on Executive Functioning Deficits
    • Medicaid & Medicare Network Adequacy >
      • OIG: STATE STANDARDS FOR ACCESS TO CARE IN MEDICAID MANAGED CARE (Sept. 2014)
      • OIG: ACCESS TO CARE: PROVIDER AVAILABILITY IN MEDICAID MANAGED CARE (Dec. 2014)
      • GAO 15-710: MEDICARE ADVANTAGE: Actions Needed to Enhance CMS Oversight of Provider Network Adequacy (Aug. 2015)
      • CMS: Promoting Access in Medicaid and CHIP Managed Care: A Toolkit for Ensuring Provider Network Adequacy and Service Availability (April 2017)
    • Medicaid Mental Health & Substance Use Disorder Parity >
      • CMS Parity Compliance Toolkit Applying Mental Health and Substance Use Disorder Parity Requirements to Medicaid and Children’s Health Insurance Programs [Jan. 17, 2017]
      • Frequently Asked Questions: Mental Health and Substance Use Disorder Parity Final Rule for Medicaid and CHIP [CMS October 11, 2017]
    • Olmstead Disability Rights >
      • Statement of the Department of Justice on Enforcement of the Integration Mandate of Title II of the Americans with Disabilities Act and Olmstead v. L.C. (2011)
      • Comprehensive Olmstead Planning
      • the Logical Long Term Consequences of our failure to provide Intensive Community MH Treatment
      • Olmstead Nation ---State Pages: How Far to Comply with Olmstead?
  • Take A Walk Around Orchid's Resource Block
  • Colorado Abuse & Neglect Scandals Involving People with Disabilities
  • Mental Health By The Numbers
  • New Science Is Amazing AND It Has HUGE Moral Implications for Our Society: NOW
  • Olmstead & Homelessness
  • Double V
  • " 'Defund the Police" Means 'Invest in the Resources Our Communities Need' " or Don't Cost Shift to the Police
  • VAGUE OLMSTEAD PLANS, EXPENSIVE LITIGATION
  • Updating & Reforming our Understanding & Treatment of "Anti-Social Personality Disorder" Blog
  • Reform of " Anti-Social Personality Disorder" in Criminal Justice
  • CO HB22-1278
  • New Understandings Matter
  • Mental Health, Ethics & Law
  • CO Olmstead Disability Homeless Law & Policy Project
  • Inflammation, the Immune System, Neuro-Developmental Disorders, Psychiatric Disorders, Substance Use Issues & Chronic Disease
  • Microglia and the Brain's Immune System
  • Substance Issues & the Immune System