The regulation as written is open to wide interpretation to the extent that it is not guidance at all. Most of the operative terms are undefined.  It should be very clear what will be taught, how it will be taught,  and how such instruction is expected to be actionable.  

Lack of clarity could result in abuse, waste or unintended consequences. 

The clarified terms and approach should be justified by studies showing positive results measured against clear criteria. 

The proposal should not be adopted until these issues are addressed.