Thank-you for the opportunity to provide comments and suggestions for further improvement.

Overall comments: An electronic version of the checklist would be useful for example:

• The physical space for comments varies in the paper draft version. An electronic version would allow expansion of space only when needed, resulting in an efficient final document.

• The draft has not reduced the voluminous requirements of initialing and dating by the supervisor in each section, along with signatures at the end. Electronic signatures at the end of the checklist would be sufficient and eliminate the requirement for initials and dates in each section.

Comment: Definitions: It is recommended that the requirement change to allow for the "competent" level (vs. proficient) to be acceptable for a DSP to begin providing billable services. The definition of "competent" states; "The individual demonstrates all of the skills of actions in column two, but not on a routine basis as appropriate to the skill or action;  low level of supervision needed. Competency refers to the bare minimum required for acceptability". This should be rephrased to say, "Competency refers to the minimum requirements for acceptability".