I noticed a significant change in the provider manual (that's not in the new DD waivers regulations) in the area of authorization period length for Skilled and Private Duty nursing. Currently, the authorization period is a maximum of one year, in line with an individual's ISP year dates, but the manual shortens that max to every 6 months. This would pose a significant issue for providers in keeping track and resubmitting service authorizations. Please keep the requirement at once a year instead of twice. While the intent seems to be to be proactive I don't think you will be able to corollate this into improved health overall. I don't believe the returns will justify the costs in that there will be double the administrative work (time and money taken away from direct care of the individual) for questionable amounts of improvement in health outcomes that you won't even be able to statistically link to this change because of the many other coexisting variables.