To provide these level of services versus the minimum and maximum approved hours per month per consumer/client/member, etc, does not allow for an appropriate amount of time spent with them in the community to be effective! In rural Virginia, sometimes, it can take 45 min to 1 hr in one direction just to get someone to a viable appointment. If we can only spend 1 to 2 hrs per week with someone, there is no way we can measure any kind of progress or lack thereof. 

 Additionally, whereas these community programs are the core of our overall budget, the reduction in hours per month cut us specifically across the board at 75%. That will put us out of business. 

You are increasing the requirements of providers which is fine but yet also reducing the large amount of measureable time that we can spend with each consumer. 

We believe you should reevaluate the amount of time (hours) per month/per tier that you can spend with a consumer. There is a minimum need of 8 hours per week that is needed effectively determine progress or lack thereof of each consumer.