Has The Time of the QIDPD Ended?

Last year CMS modified and updated the ICF/IID regulations which included changes to the QIDP tag, W159.  In the guidelines section a specific line has drawn attention across the nation, including Texas, " The QIDP function may not be delegated to other employees even though the QIDP cosigns their work." (CMS Regulations)

Texas was quick to note this change in Provider Letter 15-12 (April 29) to the CMS (Letter).  Texas specifically noted the following:

W159 (42 CFR §483.430(a)) states that each client's active treatment program must be integrated, coordinated and monitored by a qualified intellectual disability professional.  The new W159 Guidance states, “The QIDP function may not be delegated to other employees even though the QIDP co-signs their work.”

With the new modification several states will have to consider what to do about their QIDP - Designees (QIDPD).  Several states have used non-degreed persons to serve the function of the QIDP and have done so for well over twenty-thirty years.  Although different states have had different guidelines (here is Indiana's from 2010 page 12: Link for example) the basic rule has been the QIDPD has experience with people who have developmental disabilities much like the QIDP; however, they do not have the four year degree required.  In state's like Texas, a QIDP would simply sign off on the work of the QIDPD and surveyors were happy as long as the needs of the individuals were being met.  As you can imagine, with budget cutbacks and a shortage of QIDP's (one of the reasons for My QIDP) several facilities will have to address the new rule.

Surveyors in Texas are already informing agencies about the changes, and agencies are scrambling to find solutions.  The rule indicates that the QIDP can not simply sign off on the work anymore.  This means that the QIDP essentially has to do the work even with the QIDPD there.   The problem goes further in that the rules give guidelines that a facility must have the right number of QIDP's to meet the needs of the people served.  The standards does not indicate what that ratio is, and that alone may be the saving grace for the QIDPD.  Because of this wording, agencies have a couple of options.  First, make no mistake, a QIDP function will have to be in place.  However, here are some options to keep the QIDPD involved:

1.  Keep the QIDP involved in staffings and other requirements as required, but have the QIDPD type the staffings, reports, data, and other information.

2.  Designate the QIDPD to handle a lot of staff training issues.

3.  Consider looking into the QIDPD obtaining a degree.  Many degrees can be obtained online and some have rapid programs now.

4.  Pair your QIDP and your QIDPD as a team.  If your QIDP has been handling a caseload of six, for example, and your QIDPD has been handling a caseload of six, give all twelve to the QIDP, but have the QIDPD work directly with the QIDP.

5.  Look at other options for your QIDPD to do.  Can the QIDPD help with finance, computer inputs, monthly state reports, etc?  If so, redistribute some duties to the QIDPD to balance the work load.

With the right modifications the time of the QIDPD will not be over.  Whatever your organization decides to do, two things are apparent.  First, you will have to address these changes and you'll have to address most likely without any additional funding.  Second, if you find yourself stuck in a bind, you can always contact My QIDP (MYQIDP.com) and we can provide support or the QIDP function to meet your needs.