As a Service Facilitator, I am concerned that this proposal undervalues the amount of work that occurs between scheduled assessments and visits. Much of Service Facilitation is problem-solving that happens when something goes wrong. When an attendance cannon be enrolled, payroll is incorrect, an authorization does not match the individual's needs. documentation is rejected, an EOR does not understand a requirement, or a family's circumstances suddenly change, the Services Facilitator is often the person helping identify the problem, determine who needs to be contacted, and follow the issue through to resolution. Those responsibilities cannot be adequately evaluated simply by comparing the number of required contacts under one model with another. 

Before eliminating Services Facilitation, I respectfully request that DMAS explain which current Services Facilitator responsibilities will transfer to Support Brokers, which will transfer to the F/EA or another entity, and which will no longer be performed. DMAS should publish a side-by-side comparison of these responsibilities, along with Support Broker caseload standards, qualification requirements, response-time requirements, supervision standards, escalation procedures, and performance measures. Without this information, stakeholders cannot meaningfully evaluate whether the proposed model provides an equivlaent level of support.