Regarding the proposed amendments to CHAPTER 105 (RULES AND REGULATIONS FOR LICENSING PROVIDERS), I would strongly urge that proposed definition in Article 2 of Group Home be revised by deleting the words "who do not live in the home".  As drafted, the proposed definition is biased toward one care model and would appear to exclude a care model that involves care providers who reside with persons receiving services. The model involving live-in care providers has proven over decades to be extremely effective, both greatly enhancing the quality of services within the group home and better integrating the group home within its neighborhood. Live-in care providers are inherently more invested in the quality of the group home experience, develop higher quality relationships with the persons with disabilities, and are more easily retained thereby reducing disruptions to the residents receiving care. These comments are based on over three decades of close familiarity with group homes employing this model in Northern Virginia and Washington DC, including service as a board member of one such group, as well as involvement with group homes in DC and Maryland that do not have live-in care givers. Both care models are valid. The proposed amendments should not exclude either.