Regarding EOR not being able to be an LRI -

This is not only unacceptable, it is contradictory within your own document.  You state:

"2. The person acting as the Employer of Record must not be another legally responsible individual, including a
stepparent"

However, this directly conflicts with this earlier paragraph:

"Individuals choosing to receive services through the CD model may do
so by choosing a services facilitator to provide training and guidance needed to be an employer. If the individual is unable to independently manage his/her own CD services, or if the individual is under 18 years of age, a spouse, guardian, adult child or parent of a minor child must serve as the employer on behalf of the individual."

So, please explain to me how you can require a guardian or parent of a minor child to serve as the employer, yet you say if another parent is an attendant, the first parent CANNOT be an EOR.

Also, any families who live a distance away from their other relatives (350 miles for us), who can we possible ask to be the EOR for free, that we would trust to hire and fire those working with OUR children, and see personal data on OUR children.

It doesn't seem like you really care about children with disabilities, because you're trying to make this as difficult as possible on those of us who struggle with this every day.  If you had children on the waiver, you would never think this is ok.