I am very concerned about what appears to be a very heavy reliance on entities that are external to Virginia State Government - eg

• requirement for accreditation which may or may not be timely completed based upon the workload of the accreditation agency
• training requirements for assessment tools and service plans which are essential components but not necessarily accessible for providers in a timely cost effective manner
• MCO oversight of basic activity which will be fragmented, not timely, time consuming and costly - for example the 6X external review of every Licensing CAP, notification if an emergency crisis call is made, etc
• CEP-VA as the repository for staff records . . . assuming they will attempt to monitor compliance, it will be duplicative of, or contrary to, the actions required by regulation and will not be subject to APA rules

However, the single greatest concern is that the cost and admin burden associated with any or all of the activities described above appear specifically designed to make it virtually impossible for smaller provides to survive.   If that is the intent, then perhaps it would be best said now.