I am strongly opposed to the proposal to eliminate Services Facilitation as a standalone service and replace it with Support Brokers employed through the Fiscal-Employer Agent.

One of the most important parts of consumer-directed services is exactly what the name implies: consumer direction and choice. Families and individuals receiving waiver services should continue to have the ability to choose their own Service Facilitator and develop an ongoing relationship with someone who understands the individual, the family, their attendants, and their unique circumstances.

Our Service Facilitator provides much more than assistance with paperwork. We have developed a relationship with someone who knows our family, understands our needs, can answer our questions, and provides personalized support when we are trying to navigate an already complicated Medicaid system. That continuity and personal relationship are extremely valuable to us.

I am very concerned that moving Services Facilitation under a large Fiscal-Employer Agent will result in families being assigned Support Brokers rather than having meaningful choice. I am also concerned about the possibility of frequent staff turnover—a “revolving door” of Support Brokers that requires families to repeatedly explain their circumstances and rebuild relationships with new people.

For families caring for individuals with disabilities, navigating Medicaid waiver requirements is already time-consuming and complicated. We should not lose a trusted, knowledgeable professional who knows our family simply because the state has decided to consolidate services under a larger administrative structure.

Consumer direction should mean more than choosing an attendant. It should include the ability to choose the qualified professionals who help us manage consumer-directed services.

I respectfully ask DMAS and CMS to reconsider eliminating Services Facilitation as a standalone service. At a minimum, waiver members and their families should retain the ability to choose their Service Facilitator/Support Broker from qualified providers rather than being limited to staff employed or assigned through the Fiscal-Employer Agent.

Please preserve choice, continuity, individualized support, and true consumer direction for Virginia's waiver members and their families.