I am writing as the Legally Responsible Individual (LRI) for my 14-year-old niece, who relies on the Commonwealth Coordinated Care (CCC) Plus Waiver to manage Lennox-Gastaut Syndrome, complex seizure clusters, and profound daily care needs. I strongly oppose the proposed elimination of standalone, independent Services Facilitation agencies in Virginia.

Our current Services Facilitator is uniquely qualified because they possess a comprehensive, multi-generational scope of expertise—successfully supporting clients ranging all the way from toddlers to grandparents. Phasing out localized, versatile Services Facilitators and replacing them with a distant, centralized statewide "Support Broker" creates severe operational hazards for families like ours for the following critical reasons:

* Loss of Specialized, Adaptive Advocacy: A centralized state contractor cannot replicate the deep, hyper-local knowledge that an independent agency provides. Our facilitator understands the entire lifespan of care, allowing them to provide nuanced insights that protect my niece as she grows. A centralized state broker will inevitably become a bureaucratic bottleneck.

* Compounding Administrative Burnout: As an LRI, my primary focus must remain on direct, life-sustaining clinical oversight—including managing intricate multi-medication schedules, VNS implants, and unpredictable, long-lasting seizure clusters. Forcing families into a rigid, centralized system right alongside the stressful rollout of new Electronic Visit Verification (EVV) tracking rules and the CareAttend app creates an unsustainable administrative burden. 

* Erosion of Consumer Choice: The core philosophy of consumer-directed waivers is choice. Stripping families of the right to choose an independent agency that aligns with their unique household dynamics directly contradicts the intent of Medicaid home and community-based services.

Centralizing this system under a single state umbrella will not improve care monitoring; it will isolate vulnerable families, remove essential checks and balances, and destabilize the local networks we rely on to keep our loved ones safe at home. I urge DMAS and the General Assembly to halt this transition and maintain standalone, independent Services Facilitation.