We believe that the CMS fingerprinting requirements will present significant challenges to organizations that provide DD Waiver services.

As an ESO with more than 60 Job Coaches who might have occasion to provide DD Waiver supports, this regulation will present a substantial administrative burden to our organization and to our staff.

We currently perform annual background checks on more than 70 employees and the fingerprinting requirement seems excessive and unnecessary.

Additionally, we believe that this requirement could very well have a negative impact on our ability to recruit new staff members, and like most providers we are already struggling to recruit and retain DSP’s / Job Coaches.    And recruitment of new staff directly correlates with our service capacity, thus resulting in fewer services being delivered to an already underserved population of people with significant disabilities.