Because these new regulations represent a significant shift in the structure and delivery of services as well as the billing of those services, home-based providers are going to have to make significant business- and service-related changes to successfully transition. These proposed changes affect nearly every aspect of doing business (i.e. hiring, service delivery, training, billing, payroll) such that successful implementation will take a quite some time. I am therefore requesting (in addition to my previous commentary regarding specifics of the proposed regulations) that a considerably longer period of time be granted to allow agencies and MCOs to make the necessary infrastructure and service delivery adjustments. Please also consider that making these changes will be even more difficult at a time when we are all trying to manage business in the midst of this pandemic, and throughout the holiday season when many employees take time off to be with their families. My proposal would be an effective date of 3/1/22 to allow agencies and MCOs 90 more days to make any needed changes. Thank you for your consideration.