Who is the unpaid caregiver in a group home or facility?  Or coming from an agency?Discriminatory practice-discrimination against families in favor of big business profiting on the backs of the most vulnerable. 

You have already arbitrarily imposed an artificial structure of employee/employer relationship on families. Why not just directly reimburse for services provided at a living wage? For all of the hours they are provided. Reduce bureaucracy.

Look at health outcomes and safety-with real data.  These policies are written with the prejudiced eye of social workers who try to see families as suspects and fraudsters. This is not ok.

Have the consumers write policies that meet their needs.

In home, EOR's are the only ones who can actually supervise and ensure that the hours are worked.  There is no conflict of interest. Just different roles.

It's an artificial role, anyway, designed to meet the needs of a dysfunctional system.  Why not just give this role to the fiscal intermediary? The authorizations are already set up.

Please reconsider the proposed changes, and keep the current provisions in place, as they are. Consumer-directed doesn't pay for the 24 hour care that actually goes on.

Both my spouse and I gave up our careers to take care of our daughter who has 24 hour severe needs.

We already have double oversight from two agencies.  Wouldn't one monthly visit be adequate? Yes, ensure the safety of individuals with disabilities-the system is already in place.

There are going to be terrible consequences to individuals with disabilities if you roll this out. Virginia be smart.