245D documentation requirements: the 2026 checklist

1. Policies and procedures — every 245D provider

Drug and alcohol prohibitions. Maltreatment reporting procedures. Emergency use of manual restraint policy. Grievance procedures. Service suspension and termination protocols. Data privacy protections. Person-centered planning framework.

Each must be current, consistent with practice, and available. The common failure is not a missing policy — it is a policy that says one thing while the staff do another. A licensor who reads your restraint policy and then reads an incident report describing something different has found a problem in both documents.

2. Additional policies — intensive support services

Health service coordination protocols. Medication safety procedures. Safe transportation guidelines. Incident response procedures.

Residential services fall on the intensive side. If you run a group home, AFC home or ICS, these apply to you regardless of size.

3. Staff training and competency records

Before a staff member begins working: orientation covering emergency handling, individual rights and maltreatment reporting.

Within 60 days: demonstrated competency in program requirements.

Annually: data privacy and HIPAA · rights of people receiving services · mandated reporting · person-centered practices · positive support strategies · bloodborne pathogens and universal precautions · first aid and CPR where required · risk reduction · implementation of individualised support plans.

All training records and competency assessments must be available for DHS review. With eight DSPs and normal turnover that is dozens of independent expiry dates — this is the single most common place small providers lose points, and it is entirely preventable.

4. Service documentation

Individualised support plans that are personalised, current and thoroughly documented, with the person receiving services actively participating in developing them.

Service delivery documented against the ISP rather than in a parallel notebook. Progress notes and outcomes that connect to what the plan actually says.

The test a licensor applies is simple: show me that this service was delivered, by this person, to this individual, on this date, and that it matched the plan. Four separate systems make that question hard to answer.

5. Incident and behavior records

Reportable incidents include serious injuries, deaths, medical emergencies, mental health crises, law enforcement involvement, unauthorised absences, and certain conduct by people receiving services.

Within 24 hours, to legal representatives, case managers and DHS Licensing. Behavioral interventions require form DHS-5148.

Keep the notification log alongside the incident itself. Proving the incident was documented is half the requirement; proving the right people were told within the window is the other half, and it is the half most often missing.

6. Staffing and operational records

Staffing schedules — a record DHS can ask for directly. Client rights acknowledgements and communications. Incident reports and maltreatment investigations. Current policies with evidence of review.

License renewal runs annually through December 31 on payment of the renewal fee. DHS reviews may be unscheduled.

A note on what software can and cannot do

Software does not make you compliant. Your policies, your training and your practice do that.

What a system can do is make compliance evidenceable — timestamped at the moment things happen, attributed to a person, and producible on request without three days of assembling paper. That is a narrower claim than most vendors make, and it is the honest one.

If you are running this on Word documents and a shared drive today, the first thing worth fixing is not the whole system. It is training expiry tracking, because that is where small providers most reliably lose points and it is the easiest thing to automate.