I greatly appreciate the agency taking steps to revise proposed regulation in response to prior public comment. That said, I have significant concerns with the new proposed guidelines. We went to CCC+ because it was impossible to find agency employed caregivers in the Northern VA metro area who could work around a child's school schedule. Every agency I contacted only wanted to place caregivers who were guaranteed 40 hours M-F from 9am-5pm. And most informed me that they had trouble finding staffing at going rates because special needs kids required so much attention. For these reasons, most informed me that going forward they would only place caregivers for adults. It was simply impossible to find agency directed care for a school-age child. Thus, the new proposed requirements would drastically limit caregiver options for most children in the area. In addition, requiring parents to somehow long in and out and provide only so called "extraordinary care" is completely unreasonable. Our children have already been found to have been disabled when qualifying for Medicaid waivers, all of their care is extraordinary. Not to mention, requiring some level of additional verification or proof would be near impossible to correctly implement or enforce. Last, the 40 hours limit puts a severe hardship on parents who require services for their children well beyond the 40-hour threshold, especially where, as set forth above, they have to fill irregular working hours that agencies are not able to fulfill. I would strongly urge the agency to adopt rules that do not require or significantly relax the EOR requirement so that it applies to most special needs kids, and to consider revising the hours to at least 50/week. If the agency wants to help root out fraud and mistakes, I would suggest considering other options, such as a training course. Thank you.