Concur with other comments on new substantive restrictions on group home size inappropriate, need to cover all days in the year at the existing pay rates, SIS inadequacy and competency requirements—all needs to be fixed.

12VAC-30-122-230---Creates the impression that the plan moving forward will be to have all reviews done remotely in B which establishes the requirement to “forward” rather than make available materials needed for the review. While the COVID period may have made remote reviews necessary, they should not be the sole standard moving forward.

The remote review process has been extremely difficult for small providers where the administrative function is typically preformed by 1 individual, who also has a host of other roles. The addition of 75-100 work hours demanded by these reviews often in very limited time frames is an onerous burden that crowds out other duties and undermines quality services. The onsite reviews consistently accomplished the same function in 6-7 work hours and hence lowered the burden to a manageable level, the were also more through and provided a more in depth review of the overall operation making the better on every front.  Continued use of remote review after the pandemic should not be allowed or the regulations should be changed to give special considerations to small businesses in the process as required by VA Law when there is an onerous burden on small companies due to a regulatory change.