I strongly disagree with the proposed change requiring personal care aides to physically attend a minimum of 12 hours of agency provided training. This proposed change would place an undue hardship on agencies who would be forced to pay employees for training with no hopes of being reimbursed by DMAS. The current method of training is adequate.

I agree with the proposed change of reducing the number of years of experience required for RNs from two to one.

I disagree with the requirement that providers shall require the supervising RN/LPN be available by phone at all times to the waiver individual. Again, this would create an additional expense for providers that would not be reimbursed by DMAS and create an undue hardship on agencies providing care. Additionally I feel that emergency calls should always be handled by 911 and that any non-life threatening issue can be handheld on the next business day.

Thank you for your review of my comments.