In 1710, A, 9 - Recommend ending this paragraph at "available".  "Emergency situation" is not defined.  The primary caregiver should have the flexibility to use the backup plan as necessary without having to worry about whetrher or not DMAS would deem it to be an emergency situation.  In like manner, 1730, A, 25 - recommend adding "or otherwise unavailable"  to the list.  If the primary caregiver had a medical or other appointment of their own and an appropriate backup was available, then per this sentence the primary caregiver could not leave because they personally were not ill, incapacitated or using respite.

I still believe these two programs are written in an overly restrictive manner and do not provide the individual with the waiver adequate flexibility and self-direction to meet their needs.  There are many restrictions for a part of the waiver that is a small fraction of the nursing costs, and as a result, there are limited options and even fewer providers. These programs are critical for successful, safe, independent living and the patient should have a better voice in making the determination of how best to spend this resource.

It is greatly appreciated that missed shifts will now be able to be made up within 72 hours after the shift is missed in 1720, B 1, C.  However, paragraphs C, (5) places significant restrictions on making up the shifts by requiring that the shifts be made up within a Sunday to Saturday week.  Not sure why this restriction was added but suggest removing it.  Also paragraphs C (5) and C (6) bothstill state maximum of 16 hours per day.  However, for those patients with 16 hours per day making up a shift will lead to more than 16 hours in a day when a shift is made up.  Recommend clarifying that the 16 hour limit may be exceeeded when a shift is made up.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

As you can see, those receiving PDN 16 hours per day are still not afforded the opportunity to make up missed shifts as the ‘shall not exceed 16 hours per day for any reason’ has not been removed from the regulation.  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

As you can see, those receiving PDN 16 hours per day are still not afforded the opportunity to make up missed shifts as the ‘shall not exceed 16 hours per day for any reason’ has not been removed from the regulation.  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I have cared for patients covered under this waiver and supervised nurses dedicated to caring for these patients. This change is not a luxury for a family trying to rip off the government, this is simply to allow families to use care that they were authorized to receive and unable to use due primarily to a shortage of nurses qualified and willing to work for the least amount of pay offered in the nursing field.  Please help these families!

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

As you can see, those receiving PDN 16 hours per day are still not afforded the opportunity to make up missed shifts as the ‘shall not exceed 16 hours per day for any reason’ has not been removed from the regulation.  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in your final regulation.

I strongly urge you to reconsider including these changes in the final regulation.

Martha Hogan

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

As you can see, those receiving PDN 16 hours per day are still not afforded the opportunity to make up missed shifts as the ‘shall not exceed 16 hours per day for any reason’ has not been removed from the regulation.  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

To Whom it may concern,

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

As you can see, those receiving PDN 16 hours per day are still not afforded the opportunity to make up missed shifts as the ‘shall not exceed 16 hours per day for any reason’ has not been removed from the regulation.  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

Respectfully,

Stephanie Kohn

.

As a relative of a family who is affected by recent decisions, I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

As you can see, those receiving PDN 16 hours per day are still not afforded the opportunity to make up missed shifts as the ‘shall not exceed 16 hours per day for any reason’ has not been removed from the regulation.  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I live here in the Richmond area and would be more than willing to sit down to talk with you about this particular request and why the change is needed.  I strongly urge you to reconsider including these changes in your final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

As you can see, those receiving PDN 16 hours per day are still not afforded the opportunity to make up missed shifts as the ‘shall not exceed 16 hours per day for any reason’ has not been removed from the regulation.  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

As a Pediatric RN who has dedicated most of my 24 year career caring for children on this waver, I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

As you can see, those receiving PDN 16 hours per day are still not afforded the opportunity to make up missed shifts as the ‘shall not exceed 16 hours per day for any reason’ has not been removed from the regulation.  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

Prior to becoming an RN, I was blessed with my own medically fragile child.  Sadly, she died at the young age of 2. It is extremely disappointing to see (30 years later) that families are still facing such easily rectified issues regarding the care of their children at home.

I live just outside of Richmond, please consider sitting down to talk with some of us about these much needed changes. I strongly urge you to reconsider including these changes in your final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

As you can see, those receiving PDN 16 hours per day are still not afforded the opportunity to make up missed shifts as the ‘shall not exceed 16 hours per day for any reason’ has not been removed from the regulation.  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

Typ

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

e over this text and enter your comments here. You are limited to approximately 3000 words.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation.

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue. However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts.

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day. Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home. To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable. This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours. Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families. The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

To Whom It May Concern,

  Shame on you!

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation.

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue. However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts.

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day. Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home. To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable. This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours. Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families. The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.Do the right thing!

Gail Kinsey

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation.

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue. However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts.

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day. Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts.   

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system. 

As a reminder, the original request was as follows: 

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I am very dissapointed to hear that the changes proposed during the public comment period last year regarding the making up of missed shifts for those recieving 16 hours of private duty nursing care per day were not implimented in the final stage of this regulation. familys that have to realy on home care for their loved ones are not even given a peiod of one week to make up the shift lost . These children cannot be left unatended, and you are leaving the family to get by without sleep or work because of this. As I have been a private duty nurse for a good time of my working life . I can tell you that it is not safe . and not fair . You need to push this through for the safeties sake . Thank you ,

                                                                                                                     Lori Flemming

Dear SIrs:

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts.

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

To Whom It May Concern:

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.  I urge you to reconsider the needed changes needed for these special children.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation.

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue. However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts.

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day. Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation.

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue. However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts.

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day. Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home. To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable. This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours. Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families. The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation.

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue. However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts.

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day. Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home. To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable. This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours. Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families. The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.

I am disappointed to learn that the changes proposed during the public comment period last year regarding the making up of missed shifts for those receiving 16 hours of private duty nursing care per day were not implemented in the final stage of this regulation. 

When the Town Hall Agency Background Document states: ‘In response to comments received during the comment period, the changes being made in the final stage are: (i) the making up of authorized private duty nursing care within the same week is permitted’, it appears on the surface to address the issue.  However, the wording in the updated regulation states the following: (5) The making up or trading of any missed [ scheduled shifts, days or authorized ] hours of care may be done within [ 72 hours the same week (Sunday through Saturday) ] of the missed scheduled shift but the total hours made up, including for any day, shall not exceed 16 hours per day for any reason.’

  Not only does this change not address the previously made comments, it allows those who could already make up a missed shift within 72 hours to now have a full week to make up their missed shifts. 

While this change from the proposed stage to the final stage may seem minor or inconsequential in its impact, I would argue that omitting the proposed comments from last year is, and has been, a substantial impact to those on the waiver - especially targeting those receiving PDN 16 hours of nursing coverage a day.  Ironically, these are the same children who have been designated as the most severely impacted by their disabilities according to this same system.

As a reminder, the original request was as follows:

When a PDN shift is missed, there are additional hardships placed on the parents/caregivers in the home.  To suggest that families whose children receive 16 hours of care per day don’t need the ‘make up’ hours is unconscionable.  This limitation should be removed and those cases receiving 16 hrs of PDN should be given the same opportunity to make up missed shifts within 72 hours.  Their need to make up missed shifts is no less than those (families who receive less than 16 hrs./day of care) who are already permitted to make up missed shifts.

In addition, it’s recommended that PDN hours be allocated on a weekly basis in lieu of a daily basis which would allow for increased flexibility to better provide for the varied needs of the recipient families.  The total number of hours used on a weekly basis would remain the same – in this case 112 (16 hrs/day x 7 days/wk), but allow for families to use them in the way that best fits their needs -- this would also allow for minor adjustments to schedules affected by missed shifts.

I strongly urge you to reconsider including these changes in the final regulation.