We are requesting that DMAS revise the proposed Family and Individual Support (FIS) and Community Living (CL) waiver amendments to permit qualified existing service facilitation agencies to perform support broker functions through written agreements with the fiscal employer agent (F/EA), subject to state approval, procurement requirements, and clear contract oversight. The General Assembly has directed a transition away from service facilitation as a standalone service. Our recommendation addresses how to carry out that direction while preserving continuity, meaningful choice, and accountability.
The draft FIS application schedules Regions 1 and 3, including Southwestern Virginia, for March 1, 2027. It requires a support broker visit within 90 days of regional transition and an initial face-to-face visit within 10 days for someone newly entering consumer direction. Support brokers will assess needs, develop or adjust plans of care, submit service authorization requests, train employers of record, and remain available between visits. This is a substantial workforce and contact obligation in a short implementation window. Existing qualified agencies already know many of the individuals, families, local travel patterns, and service records involved.
The draft includes a 90-day authorization bridge and information sharing. Those are useful safeguards. They do not, by themselves, establish enough qualified local capacity or a practical path for an individual to retain a trusted support relationship. We ask DMAS to specify how the bridge will be monitored and extended or otherwise resolved if a visit, assessment, or authorization cannot be completed on time. Rural travel and limited provider capacity should be accounted for before Southwestern Virginia is launched.
The draft describes a single F/EA contract for the broker function. Selecting an F/EA or payroll administrator is different from selecting the professional who visits the person, trains the employer, and helps resolve service issues. A qualified partner network could preserve a meaningful choice of support broker while placing contract responsibility and day-to-day oversight with the F/EA. DMAS should review the current contract and procurement authority before adopting this model; the proposed amendment should make the pathway explicit rather than assume subcontracting is already allowed.
“Subject to applicable procurement law, DMAS approval, and express authorization in the F/EA contract, the F/EA may perform support broker functions through qualified agency subcontractors or other approved business-to-business arrangements. The F/EA remains accountable to DMAS for all support broker duties and shall monitor qualifications, timeliness, quality, privacy, conflicts of interest, geographic coverage, complaints, and corrective action. An individual or employer of record may request an available qualified support broker or agency partner, including an existing services facilitation provider that meets the published requirements. DMAS and the F/EA shall provide an accessible reassignment and escalation process and shall maintain service and authorization continuity during transitions.”
We ask DMAS to add this authority and these operational safeguards to the FIS and CL applications, align the F/EA contract before rollout, and invite existing service facilitation agencies to apply through a fair published process. Please also publish region-level readiness and transition measures so participants and officials can see whether the model is working.