Please review the barrier crime statues, they are different than from those currently used. 

EOR definition should be expanded to reflect current practice

EOR reference throughout should stand alone when speaking of employer responsibilities.

MFP definition should be expanded beyond transition services

Throughout the regulation, SF and providers are referenced separately, SFs are providers and therefore there is no need for the separate reference.

12VAC30-120-924

B.2..b. Please clarify that individuals that cannot assure health, safety, welfare or back-up plan is ineligible for EDCD waiver services. 

 3.  Please clarify "timesheet discrepancies"

12VAC30-120-924

E.4.a. Respite

Current practice reflects 480 hours per FY but that does not reflect current practice of 480 per CY

F. 1. b. Why does the EOR have to maintain copies of attendant timesheets for SF review when the FEA makes all timesheet available through their webportal. 

F.2.a.4.  This statement is unclear

J.b. Transition services - institutions should be broadened to incorporate all qualified institutions