I have operated as an independent Services Facilitator for eight years. During that time, I have built a professional practice based on accountability, responsiveness, reputation, and the quality of service I provide to the individuals and families I serve. As an independent provider, I have a direct responsibility for maintaining professional standards and ensuring that the people I serve are satisfied with the support they receive.
The proposed Support Broker model raises significant questions about what happens to that professional structure. If Support Brokers will be employees of the Fiscal/Employer Agents rather than independent providers, what incentives and accountability mechanisms will exist to ensure the same level of responsiveness, individualized attention, and professional investment? This is not to suggest that an employee cannot provide excellent service. Rather, DMAS should explain how the proposed employment structure will preserve the accountability and responsiveness that currently exist when an independent provider's professional reputation and continued relationship with the participant depend directly upon the quality of service provided.
Participant choice is equally important. Under the current model, individuals have the ability to select their Services Facilitator and, when that relationship is not meeting their needs, choose another qualified provider. That ability to hire and discontinue services with a provider creates meaningful accountability and is consistent with the fundamental principle of consumer direction. Under the Support Broker model, will participants retain comparable authority to select their Support Broker and request a different broker when the relationship is not working? If Support Brokers are assigned by the F/EA, participant choice could be significantly different from the current system.
DMAS should clearly explain how Support Brokers will be assigned, whether participants will be able to choose among qualified brokers, whether they may change brokers without having to demonstrate cause, and how quickly a replacement must be provided. A system described as consumer-directed should not reduce the consumer's ability to choose the professional who assists them in directing their services.
There is also a broader workforce issue that deserves consideration. Virginia already has experienced Services Facilitators who have spent years developing expertise in consumer-directed services and building businesses specifically to serve this population. DMAS should explain what role these experienced independent providers will have under the new model and what analysis has been conducted regarding the potential loss of experienced providers from the consumer-directed services workforce as a result of eliminating Services Facilitation as an independent service.