I strongly oppose both the proposed 56-hour weekly soft cap on personal assistance and the proposal to eliminate the current Services Facilitation model and replace it with Support Brokers.

As the parent of a child with developmental disabilities, I believe waiver services should continue to be determined by the individual needs of the person receiving care, not by an arbitrary number of hours established across an entire population. Every individual with a disability is different, and their needs do not conveniently stop after 56 hours in a week.

While this is being described as a “soft cap” with the possibility of exceptions, I am very concerned about what that will mean in practice. Families should not have to repeatedly prove that care already determined to be necessary is still necessary simply because it exceeds 56 hours. An exception process can create additional paperwork, delays, inconsistent decisions and interruptions in care. For families caring for individuals with significant disabilities, even a temporary reduction in authorized assistance can have serious consequences for the individual’s safety and the stability of the family.

I am also strongly opposed to eliminating Services Facilitation and replacing established Services Facilitators with Support Brokers working through the Fiscal/Employer Agent. Consumer-directed families need knowledgeable, accessible professionals who understand the individual, the family and the complexities of managing consumer-directed care. A Services Facilitator is not simply someone who completes paperwork. They provide guidance and support to families navigating a complicated Medicaid system and help ensure that consumer-directed services are appropriate and functioning properly.

I am concerned that moving this responsibility under the Fiscal/Employer Agent will reduce families’ choice, disrupt established relationships and create a more centralized system with less individualized support. DMAS should strengthen Services Facilitation where improvements are needed rather than eliminate the service entirely.

Families of individuals with disabilities already carry tremendous responsibility. Changes intended to improve efficiency should not result in additional administrative burdens or make it harder to obtain and maintain necessary care.

I respectfully urge DMAS to withdraw the proposed 56-hour soft cap and reconsider the elimination of Services Facilitation. Virginia’s waiver system should remain person-centered, protect continuity of care, preserve meaningful choice, and authorize services according to each individual’s documented needs rather than a predetermined weekly threshold.