I am writing to strongly oppose the proposed 1915(c) waiver amendments that seek to implement a 56-hour "soft cap" on consumer-directed Personal Assistance (PA) and eliminate Service Facilitation by transitioning to Support Brokers. These changes will severely threaten the health, safety, and independence of Virginia’s most vulnerable citizens.

1. Opposition to the 56-Hour Cap on Personal Assistance

Limiting care to 56 hours per week does not reflect the real, everyday needs of individuals with significant developmental disabilities. My daughter relies on these authorized hours for critical daily needs, requires, shopping, meal preparation, hygiene, dressing, laundry, medication, entertainment, transportation, emotional and behavioral support etc., and one can not just choose not to respond when these needs occur beyond a neat hour cap.  In addition, she  has severe insomnia and wakes up frequently throughout the night to use restroom and need help cleaning to prevent her from her herm. She also requires constant supervision to ensure her safety. Capping her care at 56 hours a week forces her down to just 8 hours of care per day. This leaves 16 hours every single day where she is completely unsupported. DMAS expects me, her mother, or natural support , to work these remaining 16 hours every day for free. This is an impossible and unsafe expectation that will lead to catastrophic caregiver burnout and force my daughter into an expensive state institution."

Even though this is labeled a "soft cap," my family is already experiencing immense stress and receiving misinformation from support staff telling us our hours will be cut. Forcing families into a high-stakes "exception request" process creates unnecessary bureaucratic barriers, strips away independence, and will inevitably lead to institutionalization for individuals who can no longer be safely cared for at home under a standard 56-hour limit.

2. Opposition to Eliminating Service Facilitation

The proposed elimination of Service Facilitation by May 31, 2027, is a dangerous disruption to our care system. Service Facilitators are our frontline advocates. They understand the consumer-directed model and ensure that our payroll, electronic visit verification (EVV), and service plans run smoothly. Transitioning families to an unproven "Support Brokerage" system while simultaneously cutting hours will leave families entirely unsupported. Removing  Service Facilitators completely removes our only remaining safety net.

I urge DMAS and the General Assembly to halt these amendments. Virginia should be expanding community-based care to keep individuals with developmental disabilities safe in their homes, not restricting their hours and removing the professional advocates who help them survive.

Thank you