I have concerns about numbers 2 and 8 of this proposal.

While I can understand the thought process of removing service facilitators, I have deep concerns about the practicality of implementing this change. It is already difficult to schedule check-ins with the system as it exists, and I worry this will only become harder by removing service facilitators, especially since the responsibility will go to another private entity that the government can't ensure hiring is happening in time with the changes. What happens if PPL or CDCN doesn't have the staff to support the changes? Will waiver recipients lose these benefits if we can't get our scheduled check-ins on time? In addition, as an EOR using PPL for my daughter's waiver, getting in touch with PPL is next to impossible whenever there is an issue. I'm very concerned about these agencies taking over a crucial responsibility, where any paperwork hiccups can result in the loss of Medicaid coverage.

In addition, I have concerns about removing the extra review from DMAS staff when the Lever of Care determines recipients to no longer be eligible. I'd like to see data of how many times this extra review has determined that the initial assessment was accurate and how many times it resulted in a determination that the recipient is, in fact, eligible.


This data may well be available in your incorrectly tagged, 210-page document full of legal jargon that a person who doesn't work in DMAS could never hope to understand, but I personally find it abhorrent that I can't find this data easily. How is it helpful to us if the document has 10 bookmarks that all say the same exact thing? How can a screen reader user access this document if every single heading is tagged as an H1? The set-up of this document is helpful to you and not to us.