From my perspective, these proposed amendments/changes raise concerns beyond reduced oversight and service hours. They also raise questions about the long-term impact of the Texas v. Kennedy decision and the financial pressures states may face as a result.

Even in light of the Texas v. Kennedy decision, federal funding flexibility should not become a factor that leads to reduced oversight or weakened community-based supports. Before these amendments/changes are approved, what is the projected cost comparison between the current facilitator-based system and the proposed broker model, and how will funding allocated directly to client services compare under each approach? If the broker model is expected to increase administrative costs, will those costs be offset through reductions in service hours, provider payments, or other supports currently available to waiver participants?

I am also concerned about the impact these changes could have on small facilitator agencies and home health providers. Many of these organizations have spent years building trusted relationships with clients and families while providing local, personalized support. Replacing facilitators with a statewide broker model risks shifting services away from community-based providers and toward larger administrative systems that may lack the same level of personal knowledge and accountability.

Small providers are often the first to recognize changes in a client's condition, caregiver burnout, staffing concerns, or unmet service needs. Weakening their role could reduce the local expertise and continuity that many families rely on to remain safely at home.

I am also concerned by the apparent lack of public discussion from many elected officials and candidates seeking office regarding amendments/changes that could significantly affect Virginia's HCBS participants, families, caregivers, and providers. These proposed amendments/changes would directly affect some of Virginia's most vulnerable residents, yet many families have heard little or nothing from the individuals currently serving in office or seeking election. Issues of this magnitude deserve greater public awareness, transparency, and engagement from those who represent, or seek to represent, the people most affected by these decisions.

Before approving these amendments/changes, DMAS should fully evaluate how they may affect provider stability, client oversight, and continued access to community-based services throughout Virginia.