Public Comment Regarding Proposed CCC+ Waiver Amendment
Service Facilitation / Statewide Service Broker Model

I am the parent and Employer of Record for a young child with significant medical needs who receives consumer-directed personal care through the CCC+ Waiver. I am commenting specifically on the proposal to incorporate Services Facilitation into the statewide service broker model through the Fiscal Employer Agent and eliminate Services Facilitation as a standalone service.

I understand the potential benefit of simplifying the consumer-directed system. However, I ask DMAS to make sure that this transition does not remove an important layer of individualized assistance and advocacy for families caring for medically complex children.

Our family has recently experienced firsthand how administrative issues involving the Service Facilitator, Fiscal Employer Agent, authorization information, enrollment paperwork, background checks, time entry, and payroll can delay access to services or payment even when the underlying personal care services have been authorized.

For families caring for individuals with significant disabilities and medical needs, these are not simply paperwork inconveniences. An administrative breakdown can affect whether an attendant can begin working, whether authorized hours can be entered, and whether a caregiver is paid for services that were actually provided.

Before eliminating standalone Services Facilitation, I respectfully ask DMAS to ensure that the new statewide service broker model includes:

1. A clearly identified individual or team responsible for helping families resolve enrollment, authorization, EVV, payroll, and Fiscal Employer Agent problems.

2. Clear escalation procedures when an administrative or system problem prevents an attendant from working, entering authorized time, or being paid.

3. Continuity protections so that families do not lose authorized services because information, forms, authorizations, background checks, or other records fail to transfer correctly between organizations or systems.

4. A process for correcting administrative errors without requiring families to repeatedly contact multiple entities to determine which organization is responsible.

5. Appropriate accommodations and individualized assistance for families of medically complex children and individuals whose disabilities make navigating consumer-directed administrative requirements especially difficult.

6. Clear written information before implementation explaining exactly which responsibilities currently performed by Service Facilitators will transfer to the service broker, which will transfer to the Fiscal Employer Agent, and who families should contact when something goes wrong.

I also encourage DMAS to obtain meaningful input from families currently using consumer-directed services before finalizing the transition procedures. Families and attendants experience parts of this system that may not be apparent from administrative data alone.

Consumer direction can allow individuals with significant disabilities to remain safely at home with people who understand their unique care needs. Administrative modernization should strengthen that model, not unintentionally create new barriers to receiving already-authorized care.

Thank you for considering the experiences of families who depend on the CCC+ Waiver.