We are all very happy that you have decided to continue to allow parents and spouses to be paid caregivers with consumer-directed services. However, there is much more to do! First, the rule of having a non-relative be EOR is simply unreasonable. This opens up a participant and their caregivers to a whole host of problems. Their SSNs, addresses, email address, and other private information would be revealed to this person. People can barely trust their relatives, how can they trust a stranger with this information. 

Second, the limit on hours is unreasonable as well. Think about this: We are all currently having problems finding caregivers now due to the number of hours available and the pay rate. So, if a live-in is limited to 40 hours and the participant gets, say, 58 hours, then they will never be able to find someone else to work 18 hours a week. If there has to be a limit, make it so the limit is based on the number of hours each participant gets. 

You guys are definitely on the right track to helping us get the help we need. These proposed changes are in the right direction, just a bit more needed to get there!