The Commonwealth entered a permanent indictment barely 2 years ago, after the horrible treatment of individuals with a Developmental Disability.  The institutionalized language has been an issue, but what the Commonwealth is CHOOSING to do, as it should be made very clear that this is not a federal requirement - it is the state's decision, is moving backwards.  Having a 'soft cap' of 56 hours assumes that individuals with Developmental Disabilities require the same level/duration of support.  That goes against everything the DD Waiver system is about - where is the personal choice and person-centered thoughts here? This has got to be brought to the DOJ and demand extensive audits of DBHDS and DMAS, along with a pause to the state's plan to reduce the care for individual's with Developmental Disabilities.  It doesn't take a rocket scientist to look at these changes and realize that the Commonwealth is neglecting each individual who has moderate to high support needs, and furthermore, there is a very clear pathway for higher levels of residential placements here.  Isn't the whole intention of HCBS to keep individuals in their preferred home? I can assure you, group homes and other residential placements outside of Sponsored Residential, are not the collective preference of most individuals with a Developmental Disability. 

Eliminating Service Facilitators.... So, eliminate the people who know our loved ones on the DD Waiver the most so that there is no justification for hours or pathways to this 'exception' to the 56 hour cap.  It is so blatantly obvious that the Commonwealth is discriminating against individuals with a Developmental Disability.  Support Coordinators are overwhelmed, your average Care Coordinator will tell you that an individual doesn't need more than a few hours because they are ambulatory, so where does that leave our loved ones? We are not in the authorization systems to help justify hours, so by eliminating Service Facilitators, the people who know these individuals the most and provide us with an extraordinary amount of support to navigate the sloppy Medicaid & waiver system is outrageous and quite frankly, the idiocy of the people who made this decision is blaring right now. Someone sat around a table and said "Let's have Brokers who are hired by the Fiscal Agent take over this role".  So, let's turn these individuals into numbers with dollar signs above their head is what is being done. Broker? This isn't a mortgage, it's humans. And for the love of god, if it weren't for Service Facilitators, could anyone actually make it a month with no issues from CDCN? CDCN's combined IQ level is that of a pencil.  DMAS has clearly never called into the MAIN LINE and tried to work out a real-life issue with them.  Service Facilitators do 70% of CDCN's job, and I have personally witnessed it over and over as a previous Support Coordinator.  It gets even worse when you find out that most Service Facilitators aren't actually being paid for that work since many are not paid hourly or salary but instead one flat rate during home visits. In fact, the waiver network, or those with more than half of a brain, has all wondered when Service Facilitation would adopt fiscal agent duties.  But doing the opposite just truly proves what the intentions are here in the Commonwealth.  If this actually occurs, my hope is that CDCN is required to contract the current Service Facilitator agencies and not directly hire or find 'Brokers', because it would be the end of this service if CDCN or any fiscal agent is responsible for even a fraction of what Service Facilitators do.  

Please, someone needs to sue.  Contact the DOJ immediately and share concerns and bring up the settlement agreement that Virginia was in with the DOJ for so many years.