12 VAC30-50-490 A : Target Group definition needs to be clarified.  DD (no ID Diagnosis) or DD (including ID). 

12 VAC30-50-490 A1. Face-to-face every 3 months indicated here; 12 VAC30-50-440 A.1 indicates Face-to-face every 90 days - needs clarificaiton.

Recommend extending retain slot to 180 days due to challenges finding providers.

Qualifications for support coordinators for individuals with Intellectual disability are inconsistent with qualifications for support coordinators for individuals with a Developmental Disability listed in 12VAC30-50-440. E.3 

states that an individual providing support coordination needs to have a degree in human services.  As this requirement is listed only under 12VAC30-50-490, and not under 12VAC30-50-440, are we to assume this is a requirement only for individuals providing support coordination for individuals without an ID diagnosis?

12VAC30-50-490 E.7 a-f This section describes supervisory requirement, and there is no corresponding text in 12VAC30-50-440.  Are we to assume these supervisory requirements apply only to support coordinators providing services to clients without an ID diagnosis?

For E.7. a: please define Human Service Degree.

There is no corresponding section in 12 VAC30-50-440 requiring support coordinators to receive 8 hours of training annually.  Are we to assume this requirement applies only to support coordinators providing services to clients without an ID diagnosis?

Regulations regarding WSAC are not clear - states regional for BI only (not for other Waivers). BI has a separate process.  CL and FIS determined by WSAC.  Is this a change in the way this will be done or just worded incorrectly?