First of all, I like the new format and that it has streamlined in order to be user friendly and efficient. The major problem that I see in this upgrade is the demanding of proficiency with in 180 days. The job market is currently an employee job market. Making it difficult to hire experienced staff for the rate of pay which we have to offer, and inexperienced staff take longer than 180 days to become proficient in this field.  Another barrier to hiring experienced staff is our rural location. This was mentioned in another comment and I agree fully with his logic. DBHDS does not need to make getting and keeping good staff any more difficult than it already is. We are very proficient in training new staff but staff's ability to completely implement the skills being taught within the 180 days and using person-centered thinking is nearly impossible. As stated in the other comment please look at New York's model and help providers keep potential good employees.  Thank You