I am writing to strongly oppose the proposed elimination of independent Services Facilitation and replacement of Services Facilitators with Support Brokers employed through the Fiscal-Employer Agent.

My 17-year-old daughter receives services through the CCC Plus Waiver and participates in consumer-directed services. I am her mother and her Employer of Record (EOR). Because of her intellectual and developmental disabilities, she cannot manage her waiver services or advocate for herself independently.

As her EOR, I already have significant responsibility for managing her consumer-directed services. I work with her attendants, oversee their employment, deal with timesheets and other requirements, and make sure that the services she depends on are available. The independent Services Facilitator provides an important and separate role in helping our family navigate the waiver system.

I believe that independence is essential.

Under the current system, we have the ability to choose our Services Facilitator. If we are not satisfied with the person or agency providing that service, we have the freedom to choose someone else. That provides families with meaningful choice and accountability.

I am very concerned about replacing that independent role with a Support Broker employed through the Fiscal-Employer Agent. Even if Support Brokers are expected to act in the participant’s best interest, there is a significant difference between having an independent person assisting our family and having that person employed through the same fiscal-agent structure that administers important aspects of our daughter’s consumer-directed services.

If we have a problem with the Fiscal-Employer Agent, who will be our independent advocate?

That is an important question for our family. Problems involving the fiscal-agent side of consumer-directed services can directly affect our daughter’s attendants and, ultimately, her ability to receive the care she needs. Her attendants depend on the system working correctly for payroll, timesheets, background checks, required paperwork, and other administrative requirements.

If there is a problem with the Fiscal-Employer Agent, I want to know that I can turn to someone who is independent of that organization for assistance and guidance. I do not believe the answer should be to have the person assisting me be employed by the very organization with which I may have a problem.

I am also concerned about losing the continuity and knowledge that can develop with an independent Services Facilitator. My daughter cannot simply explain her needs, communicate a problem, or advocate for herself to someone unfamiliar with her. An SF who knows our daughter and our family can understand her individual circumstances and help us navigate a complicated system.

A quarterly visit by a Support Broker is not necessarily a substitute for having an independent person available when problems arise between visits. Issues involving attendants, timesheets, authorizations, Medicaid requirements, changes in needs, and other aspects of consumer-directed services do not happen on a quarterly schedule.

This change could also place additional responsibility on families who are already doing a tremendous amount to manage the care of a person who cannot live independently. As her EOR and mother, I need the independent support of someone who understands the waiver system—not simply another person within the fiscal-agent structure.

Our attendants are also directly affected. They provide the hands-on support that allows our daughter to remain safely in her home and participate in her community. Administrative problems can ultimately become problems with her care. Having an independent Services Facilitator who can help us navigate those problems is an important safeguard.

Most importantly, I am concerned about the loss of meaningful participant and family choice. If we are unhappy with our Services Facilitator, we can currently choose another one. That gives the family an important measure of control over the services intended to support our daughter.

I understand the desire to streamline Medicaid administration and reduce costs. However, administrative efficiency should not come at the expense of participant choice, independent advocacy, continuity, and family support.

If improvements are needed, I ask DMAS to improve the existing Services Facilitation system rather than eliminate its independence.

Please preserve independent Services Facilitation and the ability of individuals and families to choose their Services Facilitator and change facilitators when the relationship is not meeting their needs.

Consumer-directed services should provide individuals and their families with meaningful choice and control. For our daughter, that means having an independent Services Facilitator who is separate from the Fiscal-Employer Agent and can help our family navigate the system and advocate for her needs.