Some felt that quarterly inspections for ECCs are a deterrent to obtaining an ECC license, because of the substantial paperwork required. Some ECC providers have reported extensive survey action on the part of surveyors conducting the quarterly monitoring visits.
The official line is to only go and look at the ECC residents, and for the most part the surveyors don't have time for much more, but some are overly zealous.
Another noted similar problems to participate in the waiver program.
Administrative headaches with the ALE waiver are a problem. The more hoops that you put up for the provider the less desirable it is to be enrolled in the program. The application process is very difficult.