The proposed regulation changes contained in this draft represent a substantial increase in administrative burden and unfunded mandates which unreasonably stretch already limited resources.  I question the sustainability of the requirements contained in this document from both the provider agency and Office of Licensure.  In general, it  would seem to better serve the individuals receiving services for both providers and the Office of Licensure to be able to devote more time to the provision and robust review of services rather than the movement of paper to describe minute changes in process.  Quality and timely Corrective Action Plans would be more effective at addressing issues or concerns with a small number of providers versus adding regulations to address these situations of a few by adding substantial cost to all.

Department guidance documents are not regulations.  Their release does not follow the required process for adding/changing regulations, so such a broad statement does not have a valid place within the regulations.