To the Department of Medical Assistance Services, Office of Community Living:

I am writing regarding the proposed amendments to the Community Living (CL) and Family and Individual Supports (FIS) Waivers, currently open for public comment through October 17, 2026. My son is an adult with a developmental disability and is enrolled in the CL Waiver.

Proposed 56-hour weekly soft cap on personal assistance: This is my primary concern. My son currently has 24-hour care already approved — a combination of nursing, DSP (direct support professional), and personal assistance services. As an adult, he cannot rely on natural supports (family stepping in informally) to fill gaps the way a minor might. Personal assistance covers 13 hours per day (91 hours per week) as a fixed part of that already-approved 24-hour care mix. If personal assistance hours are capped or reduced, those hours don't disappear — they would have to be replaced with higher-cost nursing or DSP coverage to maintain the same approved level of care, shifting cost onto more expensive service types rather than reducing his actual assessed need. I am concerned about:

• How quickly and reliably exceptions will be approved for individuals like my son who have always required significantly more than 56 hours;
• Whether there will be any gap or disruption in existing authorized hours during the transition to this new cap and exception process;
• What documentation will be required to support an exception, and whether families already receiving higher hours will need to re-justify hours they have already been assessed as needing.

I urge DMAS to ensure a seamless continuation of existing authorized hours for individuals already approved above 56 hours/week, with a clear, fast, and low-burden exception process that does not require families to restart their justification from scratch.

Service facilitation transition to a statewide service broker model: Our family's service facilitator has developed deep familiarity with my son's care plan, our family's support structure, and the specific arrangements we've put in place — including who is designated to handle Employer of Record responsibilities and backup approvals across multiple family members. This relationship and institutional knowledge is not incidental; it is part of what makes his consumer-directed services run safely and smoothly. A standardized statewide broker model risks losing that continuity and forcing families like ours to rebuild trust and context with a new, less familiar system. I ask that DMAS ensure continuity of our existing service facilitation relationship through any transition, and provide clear advance notice and guidance to families before the change takes effect.

Employer of Record role changes: I support the flexibility to designate another person as Employer of Record when the individual cannot perform those duties themselves. I ask that DMAS confirm this flexibility will continue to support family structures like ours, where the EOR role and backup approval responsibilities are shared among multiple family members.

Thank you for considering these comments as you finalize these waiver amendments.

Sincerely, A Parent/Caregiver of a CL Waiver Recipient