As a long time provider to and employer of individuals with disabilities, I strongly oppose the proposed Waiver Services Section 12 VAC 30-120.  While I whole-heartedly support consumer directed services, the proposed Fast Track regulations will not protect and serve this all-too-vulnerable population.

All providers of services to clients with disabilities should meet a standard of care and training to ensure that safe, reputable and outcome-oriented services are provided. From the provider prospective, this is done through education, training and certification, all of which is reviewed via direct supervision, and ultimately, the CARF accreditation process. The proposed "Employment Assistant" will not best serve our disabled partners because not of these standards and systems of oversight will be in place. I for one can not support a system that could be detrimental to our client's recovery and possibly slow or halt their re-entry into the community.

Thank you in advance for your time and attention to this matter.

John Brauer, CEO

NW Works, Inc.

828 Smithfield Avenue

Winchester, VA  22601

jbrauer@nwworks.com