It is hard to follow, but I think this regulation change is going to impact parents of minors, taking away their ability to be attendants or forcing them to seek employment with an agency and also reducing max hours to 40.  My fear is that once the change is made for parents of minors, the next change will be to implement the same changes for parents of adults children and expand from the BI and FIS waivers to also include the CL waiver.

I became the companion for my adult child when he turned 18.  Prior to that age, when using agency directed services the agencies never could not find staff or sent individuals who were extremely unqualified to do the work.  I found 1 individual who agreed to sign up with the agency to become the attendant.  That worked for awhile but the agency drove her away with excessive requirements and non-stop mandatory meetings/trainings with no notice (and expected her to leave her other full-time job to be at those).  So, she quit.  We switched to consumer directed but still had difficulty finding attendants and eventually ran through friends and family who would do the work for a little while then quit.  Now family members won't even sign up.  So once my child turned 18, it was a relief to be able to sign up to provide the services and no longer have to worry about losing the waiver because others aren't willing to do this work.  If parents as providers is working, please leave it in place.  If you are going to pay an agency anyway, pay the parent if the parent wants that role -- they are providing a better quality service anyway.  We are always looking for non-family members to employ, but there just aren't many takers for this job given the low rate, varied hours, job duties so the parent is the best most stable service provider.  And please do not cut the hours just because it is a parent providing the service.  Base the hours on the services needed not the family status.  And remove any requirements that the parent prove they tried to hire outside attendants or obtain a doctor's note - that level of bureaucracy is not needed and serves no benefit but paper shuffling.  And please continue to allow respite care as well.  It is very much needed.