I oppose removing managed-care organizations from reviewing CCC+ service plans without establishing an equally independent and accountable replacement.

I am also deeply concerned about the combined effect of this proposal and the separate proposal to eliminate Services Facilitators. Services Facilitators frequently become advocates and problem-solvers for individuals and families. They help families understand complicated rules, address problems with fiscal agents and service authorizations, correct errors, and push back when the system is not working properly.

Families already struggle to navigate Medicaid requirements and protect authorized services. Removing existing levels of review and eliminating Services Facilitators would take away important layers of security between families and the organizations responsible for administering, authorizing, and paying for services.

Transferring these responsibilities to Support Brokers employed through the fiscal-employer agents creates a legitimate concern about independence and possible conflicts of interest. Families need someone whose primary responsibility is protecting the participant’s interests—not someone connected to an organization that also manages administrative requirements, payroll, or other program functions.

When independent advocacy and higher-level reviews are removed, I fear that errors will go unchallenged, service reductions will become easier, and families will have fewer people available to help prevent the loss of necessary benefits.

Before making these changes, DMAS must explain:

1. Who will independently review service plans and proposed reductions;
2. Who will advocate for participants when DMAS, a fiscal agent, managed-care organization, or Support Broker makes a mistake;
3. How conflicts of interest will be prevented;
4. How families can challenge inadequate service plans or reductions;
5. What qualifications and accountability requirements will apply to Support Brokers; and
6. How DMAS will ensure that these changes do not result in reduced hours, interrupted services, or lost benefits.

Virginia should strengthen independent advocacy and oversight for waiver participants—not remove existing safeguards and concentrate additional authority within the same organizations. No change should be implemented unless families retain access to a genuinely independent person who can advocate for the participant, identify errors, challenge inappropriate reductions, and help protect essential services.