District 19 would like to offer comments regarding the streamlining of waiver regulations.  While the attempt to streamline the requlations is apprciated, it is not believed that this effort wil accomplish the intended goal.  The MR and Day Support waivers have a uniqueness that does not lend them to be bundled with other waiver regulations.  Some of those unique characteristics are outlined below:

*   The assessment process and preauthorization process used with these two waivers differs from other waivers.

*   The management of the wait list (and the fact that there is a wait list) is unlike other waivers.

*   The integrated, intense role of MR case management in these waivers strengthens consumer understanding of service choices, service satisfaction, and timely resolution of any issues that may arise.

*   The relationship between DMAS and DMHMRSAS is specific to these two waivers.  The collablration of these two agencies has resulted in an evolving waiver that has been responsive to consumer needs and sensitive to redesigns to better, more quickly meet those needs.

While it understood there is some duplication in the various requlations, it is belived it would be quite cumbersome and convoluted to try to combine them and still have a clear understanding of the unique differences in administrative process, populations, assessment requirements, etc.  It is hoped that DMAS will reconsider pursuing the Omnibus Regulations.  Thank you for the opportunity to express our concerns regarding this effort.