Thank you for providing an opportunity for review and submission of public comment related to this document. Upon review of this document, I too echo the same comments that others have detailed quite thoroughly.

This document appears to be based upon interpretation that misaligns with the other components that exist within the Provider Community, in providing day to day services to individuals across the Commonwealth. The concern with this type of approach is that interpretation creates inconsistency. It has been noted by other commenters that the various departments existing within this service area approach this area with their own interpretation. Having all necessary parties at the same table in discussing this topic is needed, in order to progress forward.

One key area that is of concern relates to the notation of use of the safety restrictions form for the part V to capture HCBS modifications. The use of this forms has always remained within the catchment of human right restrictions that has been deemed necessary to ensure safety. The form references criteria found within these specific regulations. It does not appear appropriate to group potential modifications related to HCBS within this same form. Additionally, separation of the terms restrictions versus modifications is also a key area that needs focus and attention. Any modifications should be able to be reflected within the PCISP to include the Part V and not require an additional form to be completed. 

The Provider Community truly wants to adhere to the necessary HCBS requirements but the way in which this process is unfolding is resulting in confusion and difficulty. This document needs significant revisions and attention.