There is a difference between changing a policy and changing an entire system while people are still relying on it.

That distinction matters as Virginia moves from 2026 into 2027. Live-in caregivers entered October adjusting to Electronic Visit Verification. Next comes a much larger transformation of consumer-directed services: proposed limits affecting weekly personal-assistance hours, an exception process for circumstances that exceed those limits, and the transition from Services Facilitators to Support Brokers.

On paper, these changes can be separated into different policies, implementation dates, waiver provisions, contracts, and guidance. At the kitchen table, they become one experience.

Imagine a household that has used consumer-directed services successfully for years. The person receiving services has an established routine and an attendant who understands that routine. The Employer of Record understands the current system. They know their Services Facilitator. They know how to submit time and whom to call when there is a problem.

Now begin changing the pieces. The attendant learns a new EVV process. The household learns that the way attendant hours are handled may change. They must determine whether the proposed 56-hour threshold affects them. If it does, they may need to learn an exception process that did not previously exist. The person who helped them navigate consumer direction may now operate under a different Support Broker model.

Perhaps each individual change can be explained. The real question is whether anyone has tested the experience of going through all of them. That is where Virginia's implementation planning deserves greater scrutiny. A Medicaid agency can assign responsibilities across departments, contractors, managed care organizations, Fiscal/Employer Agents, and Support Brokers. A family cannot. When something goes wrong, the family simply needs the problem fixed.

They should not have to determine which part of government owns the problem before someone will help them solve it. Virginia should therefore conduct something remarkably simple before moving further into implementation: walk through the new system as though you were the person who actually had to use it.

Start with a consumer receiving significant personal-assistance services. Follow that person through EVV, payroll, attendant scheduling, Support Broker interaction, the 56-hour threshold, an exception request, a missed clock-in, a disputed payment, and an urgent service problem.

1. Count every form.
2. Count every telephone call.
3. Count every login.
4. Count every deadline.
5. Count every approval.
6. Count every handoff between organizations.

Then calculate how long it takes to get a problem resolved.

That would tell policymakers far more about whether the new system is ready than another implementation presentation.

There is another concern: timing. A phased or “soft” launch may sound reassuring from an administrative perspective. It does not necessarily feel soft to the people included in the first phase. Their paychecks are real. Their attendance schedules are real. Their need for assistance is real. A person does not stop needing help getting out of bed because Virginia is testing a new process.

The first people affected by implementation cannot become the Commonwealth's unpaid quality-assurance department.

If Virginia intends to move forward with multiple changes, safeguards should already be operational before the first household encounters them. There should be one understandable implementation calendar, clear instructions, sufficient personnel to answer questions, defined turnaround times, continuity-of-care protections, protections against lost wages caused by administrative failures, and an escalation process with someone empowered to actually resolve a case.

There should also be a trigger for reconsideration. If implementation begins producing significant payroll problems, large exception backlogs, loss of attendants, or interruptions in authorized services, Virginia should not simply continue because the calendar says the next phase has arrived.

A rollout schedule should never become more important than the people the program exists to serve.

Consumer-directed care helps people live, work, attend school, participate in their communities, and remain in their homes. That system can certainly be improved. But changing several of its foundational pieces within a short period requires more than technical readiness.

It requires knowing that the new system will still work when someone actually needs care on Monday morning. Do not rebuild the plane while people are still flying in it.