I  am writing to you reconsider EOR requirement that another LRI can not be the EOR. 

Our personal situation my husband was in the military when we moved to Virginia. He retired  and our plan was to move to our home state where all our family and friends live. Well I became pregnant had complications and my child was a micro preemie and has many complex issues and is total care. We decided to stay since all his doctors and care were already established. We had a hard time hiring trustworthy aides/nurse. We had some scary situations. Nurses we suspected were on drugs, stolen items, doing laundry cooking in our home while we were out doing errands. We had aides quiet and locked out of our home picking up packages outside that were mailed to our home. The best thing that happened to our family unfortunately was the pandemic where my spouse could be a paid care taker. The stress level for me dropped I knew I could be doing things without worrying about my child safety that he was well taken care of and loved. I would like for you to reconsider the requirement that LRI can not be an EOR. We have no family with 50 miles or friends. We moved due to military we should not be punished for my spouse serving his country and leave everyone behind so he could serve his country and also because we stayed for our son to have continuity of care. Please we beg to reconsider this requirement. We thank you for letting the parent to be a paid caregiver. 

2. "The person acting as the Employer of Record(EOR) must reside in the individual's local community within a 50-mile radius. "
"The Employer of Record may not be another LRI."

Comment and Recommendation:
These two requirements make it very difficult for families to find an EOR due to the various circumstances of families - moving frequently due to military or civilian jobs.  The EOR volunteer role involves knowing highly personal information about the waiver member, leaving families worried about finding a trusted person within a 50 mile radius.  By prohibiting the other LRI to be an EOR, the difficulty of obtaining an EOR is compounded.  It is recommended that these two requirements be removed or that an alternative is provided to address what will be a hardship or impossibility for children and spouses needing personal care.