To the authors of this manual, thank you so much for creating this much-needed guidance.  I think that it will really help providers further navigate the process of caring for someone who receives DD waiver assistance. 

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.  The waiver nursing service authorization request process is not quick or easy.  A provider has to keep track of the varying timelines and deadlines which may be different for each individual they serve, obtain multiple signatures from PCPs who are often hard to pin down in a timely manner, keep up with the ever-changing requirements from DBHDS service authorization, navigate their local CSB's staffing situations so that they can ensure that someone knows there's a service authorization request ready to be passed on, I could go on and on.  Please keep the requirement at once a year instead of twice.  I get that the intent, the spirit of the every "six months" requirement is to ensure that more health issues are seen and treated before they have a chance to turn into big problems and I agree with that intention; however, I don't think that this is a good way to do that.  The returns will not justify the costs in this scenario; 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.  Double the administrative work in the hopes of improved health outcomes that can only be linked to that increase as correlation, not causation, isn't a good use of resources.  Please reconsider that change.  Thank you for your time.