The draft sets strict caseload caps, supervision ratios, unit limits, and service-hour requirements without accounting for the realities of in-home service delivery.

• Travel time, workforce safety, family scheduling, and crisis unpredictability are not addressed.

• Tier Two Rehabilitation Skills Practice is required to be exclusively in-person, which is not always feasible in rural or high-risk environments.

• The unit cap makes it nearly impossible for staff to maintain full-time hours or a sustainable income. This will force providers to increase caseloads to compensate, which ignores long drive times in rural areas where a one-hour session may require more travel than service time. There's no way we will keep even our current staff if you tell them they can do less than they do now without the hours to meet full-time, staff will be forced to look for work else where- double check those numbers

• Many staff already hold multiple jobs to meet cost-of-living needs; further restrictions on units and caseloads will worsen workforce instability.

• It’s already difficult to meet the staffing needs currently, creating long wait lists, gaps in services and wearing down the current staff