We were extremely disappointed when reviewing these regulations for we were under the impression that the final regs would bring the ID & DD services more in line with one another.  These regs are still separate in nature and there are a significant amount of inconsistencies throughout.  It has been extremely difficult to follow the emergency regulations as well as review the draft regulations due to the significant volume of pages with strike throughs.  Inconsistences include the Definition of services of 12VAC30-50-440-D is different from 12VAC30-490D; why is that?  There are inconsistencies in the qualifications for support coordinators for ID and DD in reference to degree, experience, and KSA's.  The age for the Wait List target group is different; for DD it's six years of age.  Does that mean children under the age of 6 are excluded and cannot received Waiver or be on the wait list? 12VAC30-50-490 E.2.(i) states the SC shall not be the direct care staff person.  This is in conflict with 12VAC30-122-150 A.2.e. which states the individual SC may also function as the service facilitator.  Based on Conflict Free Case Management the SC should not be permitted to serve in this capacity.  12VAC30-50-490c.8 & 9 referencing supervision and training are we to assume that the on hour of documented supervision every 3 months and the 8 hours of annual training only applies to support coordinators providing services to individuals without an ID diagnosis?  12VAC30-122-30B references EDCD and Tech Waiver neither of which exists.  12VAC30-122-30C references 5 months to initiate waiver services in which the current requirement is 6 months.  The preference is 6 months to allow for adequate time to locate and review service options in order to make an informed decision. 12VAC122-120A14 - not sure why we are expected to report abuse and neglect to DARS? This could possibly be a HIPAA violation?  12VAC122-120B is unclear as it relates to who should obtain the documentation and who is responsible for maintaining the documentation?  We need clarification.  12VAC122-120A15 - need clarification about direct marketing activities - does that mean providers should not advertise on tv; participate in community information sessions; website; brochures; social media;etc.   We need information that clearly states what is permitted.  12VAC30-122-190A.6. - Quarterly Visits - need clarification if expected every 90 days or 3 months; is this for all individuals supported or only waiver recipients?  Recommend anytime there is a reference to time frames (ex. 90 days vs. 3 months) they need to be the same/consistent. 12VAC30-122-200 A1 - Adult SIS used for ages 16 to 72 - many of our individuals are going beyond the 72 years and require a higher level of supports to reside in the community.  What is the reason why the SIS assessment is not completed for this age group? Final note, we have concerns about the significant amount of inconsistent and incorrect information throughout and recommend not being approved until these items have been accurately addressed.