I strongly oppose eliminating Service Facilitation and replacing it with support brokers employed through the Fiscal-Employer Agent.

The person who is disabled must be the center of this decision. That person depends on consumer-directed care to eat, bathe, use the bathroom, take medication, remain safe, and continue living at home. When the system fails, that person—not DMAS, a fiscal agent, or another contractor—lives with the consequences.

I am the mother of an adult daughter who is nonverbal and completely dependent on others for her care. She cannot explain her needs to an unfamiliar broker or tell that person when something is wrong. Her trusted Service Facilitator--whom she chose--knows how she communicates, understands her history, recognizes changes, and knows the realities of her daily life. That knowledge develops through time and trust. It cannot simply be transferred in a file.

Virginia’s current regulation, 12VAC30-122-500, requires Service Facilitation to be available by telephone during business hours, provide help when requested, and be offered “on an as-needed basis as mutually agreed to” by the person, EOR, and Service Facilitator. The proposed model identifies no enforceable response time, caseload limit, continuity requirement, or guarantee that the person will consistently have access to someone who knows them.

Consumer-directed care is being hollowed out. The name remains while the person’s directive authority continues to shrink. More decisions are being transferred to the state, an app, or a contractor. The person remains responsible for complying with every rule and bears the consequences when something fails, yet has less meaningful control over the people and structure governing their care. If the person can no longer choose an independent Service Facilitator, what exactly is left for the “consumer” to direct?

Virginia has defended EVV as necessary for accountability and fraud prevention. Yet this proposal would remove an independent human safeguard—a professional who enters the home, knows the person, and can recognize what an electronic record cannot. An app can record a time and location. It cannot determine whether a person who is disabled is safe, understood, treated with dignity, or properly cared for.

This is not merely an administrative transition. It will end trusted relationships, reduce meaningful choice, and move Virginia further away from genuinely person-directed care.

Keep Service Facilitation as an independent waiver service. Do not continue taking authority away from the very people “consumer-directed” care is supposed to empower.