I am asking you to consider change. 
in regards to LRIs being the primary care giver please consider not needing objective written documentation. Finding people to care for medically complex individuals for a measly pay is not only near impossible its also very frightening. These individuals needing care often do not have the proper way to communicate basic needs and desires. This also means they cannot communicate abuse and neglect. Why would we want to put our loved ones in a position where they are being cared for by under paid individuals. This puts them in a vulnerable and potentially unsafe situation. An individual needing their basic needs to be performed by others would always choose a family member (often LRI). Who would rightfully choose to have strangers bathe, toilet, feed, clothe, etc them?  All individuals would choose loved ones. Its in the best interest of all involved parties. 

its hard to understand how you can put a max amount of paid hours per week on LRIs. If an individual has hours assigned to them through ADLs then this is the amount of hours it takes to keep them properly cared for. It means they require so much care its over 40 hours a week. Do you think an LRI can supplement their income with another job because they can only bill 40 hours?  No because they are still performing the job unpaid. It puts everyone in a more vulnerable situation to be able to receive basic human care and need. If an individual gets more then 40 hours a week then an LRI should be able to clock the hours they are working to provide the services. 

Respite care is absolutely critical for the well being of LRIs and in result the consumers. LRIs need respite from the job. Often time respite will come from people who do not live local but can commit to a week or 2 a year by traveling. These people are not able to be hired because they do not live local however they can come and give respite as needed when available. Its crucial to the health and sanity of LRIs who ultimately provide to the consumer and then the consumer gets better care as the LRI has received the respite and break that is absolutely crucial. Paying respite for times like Dr appts for the LRI but someone that cannot work regularly. All these provide the best scenario for all parties. 

Finally removing the requirement for service facilitator to need a college degree would relieve a great deal of hiring shortages that provide needed services to the consumer. We currently do not have a service facilitator because ours left and the company has not been able to hire a replacement. These cause hardship to consumers and companies trying to provide needed services. 

i beg that you take these issues seriously and to heart. The amount of care and support these consumers require is monumental. The improvements to quality of care services is life altering for consumers and their families.