12 VAC35-110-89. ISP Requirements:

In Section A, it references an initial ISP.  Please consider revising language to include if the comprehensive ISP is completed an initial ISP is not required.  Requiring an initial ISP separate from a comprehensive ISP can be burdensome to client and provider if this is not necessary.

12VAC35-110, Enhanced Case Management Contacts:

Please consider taking out requiring a visit in the individual's home and leaving meeting with the individual face-to-face at least every 30 days.  

Thank you for considering these comments.