Transitioning from traditional Services Facilitation (SF) to a Support Brokerage system in Virginia raises significant concerns for us - families of people with disabilities, regarding a loss of individualized advocacy, increased administrative bottlenecks, and potential conflicts of interest.
1. The brokerage model is based on cost.
Service Facilitators truly serve and support the individual and the EOR, while brokerage is a licensed middleman that connects buyers and sellers to trade financial assets. Brokers care about cutting costs, not how to best provide services for individuals with special needs.
2. Loss of Independent Advocates.
We have known our Services Facilitators for years and they help advocate for us, they write appeals when care hours are denied or capped. Brokers are tied to fiscal/administrative entities and will not provide the same level of independent advocacy. Since they are hired by CDCN they will try to limit the consumer hours rather than be an independent party.
3. Conflict of Interest.
Brokers or fiscal agents receive direct funds from DMAS, as a result they will struggle to maintain impartial support. Governing the Employer of Record (EOR) alongside brokerage duties creates overlapping oversight.
4. Administrative Bottlenecks
Centralized fiscal management (like CDCN) has faced severe hiring and processing delays lasting months. Adding to their duties, when there is already a well working system in place will harm the people with disabilities, limit access to care, and potentially even put a member's waiver in jeopardy.
Replacing localized facilitators with a broader brokerage system risks worsening these logistical gridlocks.
5. Reduced Consumer Choice
A shift toward standardized brokerage models threatens specialized, community-based relationships previously built with local facilitators. Right now if our SF is not performing their duties we can switch to another one. I have done that in the past. With the Brokerage system, we do not have any choice but are forced to be with CDCN.
RECOMMENDATION:
CDCN and PPL could become a Service Facilitator. One among many. People could have a choice if they want to go with them or not. This way people with disabilities will be able to choose rather than be forced into a new system that has not been tried.
