I have the following comments and concerns regarding the adoption assistance  and rate structuring proposed regulation:

1) Medicaid needs to be for all chidren who have adoption assistance agreements. 

2) Special service payments should not be appealable.

3) Medicaid needs to be used instead of special service payments when it is available for services. 

4) Special service payments should not be used for residential placements. 

5) Medicaid needs to be accessed and other funding before using adoption assistance funds.

6) The age requirement needs to be removed by 2018 to correspond with the Fostering Connections to Success Act and Increasing Adoptions.

7) If Rate structuring is applied to adoption assistance agreements it should follow the same format as foster care, meaning the rate could go up or down.  Rate structuring should only be for new agreements and not for existing agreements.