Please clarify the timeframe in which a person has to obtain a CBIS or QBIS. Since CBIS requires 500+ hours of direct service, and there are not currently enough CBIS training options for new staff members to complete during the orientation process, I am concerned that this will lead to staffing challenges for agencies serving this population. As a result, many clients would likely be underserved, held on waiting lists, or frequently transferred to new CMs due to increased turnover. The clients would ultimately be harmed by this consequence.