Under the newly formed Compliance, Oversight, Monitoring, and Investigations Team (COMIT) program, Disability Rights Arizona (DRAZ), formerly the Arizona Center for Disability Law, has submitted an annual report about the program’s first year and its goals and objectives under the Arizona Developmental Disabilities Group Home Monitoring Pilot Program.  

In 2019, the Governor of Arizona created a task force charged with finding ways to improve services and protection for some of Arizona’s most vulnerable residents. As a result of this task force, House Bill 2865 (HB2865) was signed into law by the Governor on June 28, 2022, amending the Arizona Revised Statutes (ARS) to include 36-595.03.

As a result of this legislation, the Arizona Department of Economic Security’s (DES) Division of Developmental Disabilities (DDD) contracted with DRAZ to implement the COMIT program, to  assist in monitoring group homes that serve members with complex needs (diagnosed with both developmental disabilities and psychiatric disorders) and investigate quality of care complaints for members who reside in these homes. This additional layer of oversight will enhance DDD’s investigative standards for addressing quality of care concerns.

Through the COMIT monitoring program, group homes that provide services to members with complex needs were evaluated to determine, at a minimum, whether:

1. The members with complex needs receive the services identified in the member’s person-centered service plan, including medication monitoring and habilitation treatment, as applicable.
2. The provision of services identified in the person-centered service plan of the member with complex needs has been effective in addressing the member’s complex needs.
3.  The services have resulted in a reduction in behaviors that interfered with the ability of the member with complex needs to live safely in the community.
4. All physical interventions used by the group home staff have complied with the behavioral treatment plan of the member with complex needs and applicable state laws.

Per the contract, COMIT is responsible for compiling a comprehensive report of all observations and outcomes during the preceding year. In year one, COMIT staff completed in-person monitoring reviews of 122 members residing in 75 group homes. The majority of monitoring reviews were located in the Phoenix metropolitan area, but reviews were also completed in Tucson, Show Low, Flagstaff, and Prescott Valley.  In year two, COMIT will continue to collaborate with DDD to improve the quality and effectiveness of services for individuals with developmental disabilities residing in group homes. Currently, COMIT is projected to complete 196 monitoring reviews in year two.

In the first year, group home monitoring included interviews with members, group home staff, and guardians/family members and record reviews, including the member’s Person-Centered Service Plan (PCSP), Behavior Treatment Plan (BTPs), Incident Reports, Medication Administration Records and Habilitation and Behavior Plan goals and progress.

As a result, COMIT provided a number of recommendations aimed at enhancing the development and monitoring of PCSPs, BTP’s, group home documentation and record keeping practices. These recommendations provide additional data to support DDD’s ongoing efforts to enhance the quality and effectiveness of these practices, which will further contribute to its mission of empowering individuals with developmental disabilities to lead self-directed, healthy and meaningful lives.

COMIT’s independent review of twelve quality of care complaints resulted in contacts with hospitals, DES Adult Protective Services, and police departments to educate them about their program and request access to records. Both DDD and COMIT staff work in conjunction to educate group homes, community organizations and protective service organizations about this initiative.

J.J. Rico, DRAZ CEO, emphasized DRAZ’s effort to implement this groundbreaking program, “The goal of the COMIT project is to ensure persons with complex needs are able to live independently and be free from abuse and neglect. I am proud of the work done in year one and am hopeful that the State will use the information we provide them to advance our goal and improve their monitoring tools and investigations.”

Zane Garcia Ramadan, DDD Assistant Director, also shared his support of this ongoing partnership, “The COMIT program and its work being done in the community to identify areas for improvement, strengthens our ability to provide effective oversight and positive outcomes for DDD members.”

Gail Lanham, DRAZ Program Manager, extends her “appreciation to members, families, guardians, and group home staff who participated in the first year of COMIT monitoring and investigations. The COMIT team is dedicated to enhancing its group home monitoring and reviewing member safety through quality-of-care investigations.”

For those interested in learning more about COMIT, the legislation is now ARS Title 36-595.03.

Disability Rights Arizona (DRAZ), formerly the Arizona Center for Disability Law, is the State of Arizona’s Protection and Advocacy (P&A) System and is part of a national network of public interest firms dedicated to advancing the civil and human rights of all people with disabilities in the community and in institutional settings. This program was funded through a contract with the Arizona Department of Economic Security.