Prohibiting a family member that is legally responsible for the spouse or minor receiving disability caregiving services from being the employer of record is completely unreasonable. Since it is a non-paid position, such limitations will place great stain on families who will need to find a third-party to act as EOR. Having a 50-mile radius requirement also prevents many families from having non-parental family members serve in the role. It also requires families to divulge private information and PII to third parties, who may not be in a position to adequately protect such information, and have no financial incentive to timely fulfill duties of the role. It appears to be a draconian requirement to make it difficult for many families to take advantage of being permitted to have parents serve as caregivers. Request that this limitation be removed.