Thank you for the opportunity to review these regs.  In reading them, I have questions.

Why does the backup caregiver have to be without compensation?

Assistive Technology and Environmental Modifications are in both this waiver and DD Waiver; however, there are differences in their rules.  Please make these rules more like DD waiver.

The definition of monitoring conflicts with other language in how they can be performed.

I've heard VDSS doesn't license assisted living facilities with 4 or less people.  Why is there language about VDSS licensed assisted living facilities with 4 or less people then?

Where are the requirements for EVV?  Why is there no reference to EVV?

Please loosen the requirements of PERS.  This language refers to outdated technology and does not consider modern technology like cell phones.  Why can't a person receive PERS and personal care supervision?  What if I self-install PERS?

Why can't a family member or a roommate provide PDN?

Please clarify: family members who provide personal care or respite can sign their own forms and timesheets?

Why allow LPNs to do visits if a RN has to come behind them for another visit?

Why does the SF management visit have to be done face-to-face in this waiver?  It's allowed over the telephone in DD Waiver.  Please change to be like DD waiver.

When a SF business closes, they should be allowed to send their records to DMAS in some form.