The complexity and intensity of the proposed Risk Management Plan expectations are such that they may be beyond many small organizations' ability to meet without hiring additional staff, such as a “Compliance Officer” or “Risk Manager”. Presently, administrative expectations  for DD Waiver providers are already extensive and exorbitant, and exacerbated by the historically low DD Waiver provider rates.  Additionally, the increased administrative burden prevents providers from supply “living wages” to DSPs and other supports which enhance value to the lives of the individuals we serve.