Why exchange one middleman "Facilitator" for another "Broker"?  To elimate fraud?  This does not eliminate the possibly for fraud, rather just shifts the potential for fraud from one middleman "Facilitator " to another "Broker" and even componds the potential for fraud.

Further, the proposed "Broker" is CDCN who is already contracted and fully responsible for the money end of things/distribution "Fiscal Agent" of Federal Waiver Funds.  To empower them with the "Plan of Care", too?  This would create a power vaccum.  A model for corruption.  DMAS is proposing giving all power to CDCN as both "Fiscal Agent" and "Plan of Care" Agent?  This model is ripe for corruption.

Middlemen "Facilitators/Brokers" are superfluous, because they duplicate and perform the extact same duties and tasks as County Facilitators.  We all know this obvious fact.  County Support Coordinators already fulfill the duties of "Plan of Care" Agents currently being duplicated by "Facilitators".  Why fleece the federal taxpayers with duplicating agencies performing the exact same duties?  This is most perplexing?  

CDCN fulfills the duties of fiscal agent/the money.  "Facilitators" as Agents of "Plan of Care" fulfill and duplicate the "Plan of Care" initiated by County "Support Coordinators/care.  This is a model of divided power with the caveat of "Facilitators" duplicating the duties of County Support Coordinators.

The solution for preventing a power vaccum and dividing the power is to simply provide a "Fiscal Agent" (money) and "Support Coordinator" (care).  Why complicate the service of Federal Waivers??