Imagine hundreds of business owners from across Virginia gathering to learn about the proposed Support Broker model and the future of the businesses they have spent years building to serve individuals with disabilities. When they ask fundamental questions about the transition, the repeated response is, “That’s a great question, but we don’t have an answer.”
With a potential rollout only five months away, significant questions remain unanswered. Families, providers, and individuals with disabilities deserve transparency, accountability, and a clear plan before a change of this magnitude moves forward.
At a recent meeting, a presenter stated, “A Broker is not a service; therefore, families do not have a choice.”Does changing the terminology justify removing a choice families have relied on for years? Simply redefining a service should not be a reason to diminish meaningful choice or weaken person-centered support.
We respectfully request that Virginia pause the proposed elimination of Services Facilitation until the Commonwealth and the Centers for Medicare & Medicaid Services (CMS) can demonstrate that the replacement model will protect informed choice, individualized support, accessibility, and continuity of care.
This is not merely an administrative restructuring. It could fundamentally change how thousands of Virginians receive help navigating Medicaid, resolving problems, and maintaining services that allow them to remain safely in their homes and communities.
Services Facilitators provide ongoing support to individuals, families, and Employers of Record (EORs). Their responsibilities extend beyond scheduled assessments and include assistance with:
Developing and maintaining Plans of Care, service hours, and authorizations.
Understanding Medicaid requirements, eligibility changes, and official correspondence.
Managing EOR responsibilities, attendant changes, documentation, and required signatures.
Communicating with Medicaid, managed-care organizations, and Fiscal/Employer Agents.
Addressing administrative errors, authorization delays, payroll concerns, and other problems that threaten continuity of care.
Understanding individual circumstances and following issues through to resolution.
These needs do not occur only during quarterly visits or standard business hours. A family may need urgent help when an attendant cannot be paid, an authorization changes unexpectedly, or an EOR cannot complete a required electronic form.
A trusted Services Facilitator understands the family’s history, needs, and circumstances. That familiarity can help resolve problems efficiently and prevent families from repeatedly explaining sensitive situations to unfamiliar representatives.
A quarterly visit is a scheduled encounter. Advocacy requires access, knowledge, accountability, and follow-through between visits. A call center or assigned broker cannot automatically replace a relationship built through years of individualized support.
Federal Medicaid Home- and Community-Based Services (HCBS) regulations at 42 CFR § 441.301(c)(1) establish person-centered planning protections, including support for individuals to direct their planning process to the maximum extent possible, make informed choices, involve people they choose, and select services, supports, and providers.
The central question is whether the proposed Support Broker model will preserve these protections in practice—not merely on paper.
A consumer may technically be assigned a broker but have little meaningful access to assistance if that broker is difficult to reach, carries an excessive caseload, or lacks the time to understand the individual’s needs.
Families should not automatically lose trusted provider relationships without a demonstrated need and a meaningful choice. Virginia should consider allowing qualified existing Services Facilitation providers to continue serving families who wish to retain them, including through an approved subcontracted arrangement if appropriate.
Experience administering fiscal or payroll functions does not automatically demonstrate the ability to provide individualized advocacy and timely case resolution.
Most everyone has experienced difficulties getting basic administrative paperwork processed through Fiscal/Employer Agents. These experiences raise legitimate questions about whether organizations expected to support the proposed model have the staffing, systems, and operational capacity to assume additional responsibilities. These concerns should be evaluated through documented performance data before thousands of consumers are transferred.
Before implementation, Virginia should disclose and evaluate:
Expected Support Broker staffing levels, qualifications, compensation, training, supervision, and maximum caseloads.
Vacancy and turnover rates, backup staffing, and timelines for reassigning cases when a broker leaves.
Response and resolution times, authorization delays, documentation errors, complaints, and unresolved cases.
Procedures for urgent issues, after-hours assistance, EOR changes, and continuity of services.
Access to in-person, paper-based, and other non-digital assistance for individuals who cannot reliably use technology.
The Commonwealth should establish enforceable performance standards and publish organization-level results through an accessible public dashboard. Independent audits should examine case files, documentation, timeliness, complaints, service interruptions, and compliance with person-centered planning requirements.
The public deserves evidence that each participating organization can meet its responsibilities before the existing system is eliminated.
Virginia should not eliminate Services Facilitation and only then determine whether the replacement works. DMAS should first establish baseline data on the current system, including response and resolution times, authorization processing, EOR changes, complaints, family satisfaction, caseloads, turnover, and service interruptions. If everything that works in other states is the standard, then why aren’t Va waivers the standard in every state? All states are different. Test the model here.
The Commonwealth should then conduct a limited, representative pilot with independent monitoring. The pilot should include individuals with complex support needs and families who require hands-on or non-digital assistance.
Results should be publicly reported and evaluated against measurable standards for access, responsiveness, continuity, informed choice, and consumer satisfaction. Statewide implementation should proceed only if the evidence demonstrates that the replacement preserves or improves these outcomes.
The pilot must be a genuine evaluation—not a formality after the decision has already been made.
Experienced Service Facilitators have reinforced that families need more than a scheduled visit. They need someone who understands their circumstances, answers questions, coordinates requirements, helps resolve problems, and follows through when services are at risk—including outside the traditional 9-to-5 workday.
Services Facilitation is built on knowledge, trust, and continuity. These relationships cannot simply be recreated by assigning families to unfamiliar personnel. At the same time, providers must be held accountable for quality and responsiveness.
Support stronger training, oversight, consistent standards, improved reimbursement, appropriate caseload limits, accessible technology, and reliable backup procedures. We believe Virginia can improve the existing system without eliminating the trusted relationships families already rely upon.
Respectfully asks Governor Abigail Spanberger, the Virginia Secretary of Health and Human Services, Congresswoman Jen Kiggans, the Virginia Department of Medical Assistance Services (DMAS), and CMS to:
Pause the elimination of Services Facilitation until the proposed replacement has been independently evaluated and shown to protect person-centered planning, informed choice, accessibility, and continuity.
Conduct a transparent impact analysis with meaningful participation from individuals with disabilities, families, providers, and advocates.
Independently assess prospective Support Broker organizations using documented staffing, workload, performance, complaint, and quality data.
Establish and publish enforceable standards for caseloads, qualifications, response times, after-hours assistance, non-digital access, backup coverage, and case reassignment.
Require public performance reporting and independent audits, including consumer satisfaction, complaints, turnover, unresolved cases, authorization delays, and service interruptions.
Guarantee meaningful ways for families to raise concerns, request reassignment, and obtain timely assistance when their needs are not being met.
Conduct a limited, independently evaluated pilot and publish the results before statewide implementation.
Consider strengthening Services Facilitation through improved training, reimbursement, standards, and oversight, while allowing qualified existing providers to continue serving families who wish to retain them, including through appropriate subcontracted arrangements.
Virginia’s Medicaid HCBS system should be designed around the people it serves—not administrative convenience. A structural change that affects thousands of individuals, families, and businesses must be supported by evidence, transparent planning, and meaningful public participation.
We urge Virginia’s leaders to listen to the concerns raised by families and providers, review the questions that remain unanswered, and consider the real-world consequences of removing established relationships before a replacement has demonstrated its ability to meet those needs.
Publish the standards. Establish the caseload limits. Measure performance. Audit the results. Protect meaningful choice.
At a minimum, Virginia should allow qualified Services Facilitation providers to continue supporting families who wish to retain them through an approved arrangement. Families deserve the opportunity to maintain trusted relationships, and providers deserve a fair opportunity to continue delivering the support they have built their businesses around.
The individuals served by Virginia Medicaid deserve a system designed around them—not around administrative convenience.