Thanks for the opportunity to comment. One of the genuine challenges is to ensure the integrity of the identified level of ability based on the time spent in observations in addition to other job-related requirements. It can be a useful training assessment tool if implemented as purely intended. "Agencies with DSPs or DSP supervisors who have failed to pass the orientation test or demonstrate competencies as required will be referred to DMAS Program Integrity for consideration of additional actions." What are those additional actions? Also, is there consideration for a competency checklist specific to the level of functioning of individuals served by a provider?