Page 7 – Competency 3 and all related skills must be confirmed as competent prior to providing support in the absence of paid staff who has demonstrated proficiency with this competency. – This will negatively impact Group Home, Community Coaching, Community Engagement and In-Home as the DSP’s cannot provide billable services alone prior to competency. These service lines do not fund adequately based on two staff providing the service. We cannot maintain fiscal viability to hire, train and provide each new hire with a second staff member or supervisor for all shifts until the employee gains competency; however, we provide drop in support from supervisors with new hires as well as support through our on-call system when needed. While we agree that there would need to be a competent DSP or Supervisor available during critical times until competency is established, we should not be required to provide the two staff at all times. We also continue to have a DSP shortage crisis across the state which would add another layer of difficulty with having enough people to maintain this requirement.