I am writing to strongly oppose the proposed elimination of Services Facilitation and the loss of provider choice for Virginia individuals and families who rely on consumer-directed services.

The entire purpose of consumer-directed services is to give individuals with disabilities and their families greater choice and control over the services that allow them to live safely and successfully in their homes and communities. Removing their ability to choose their Services Facilitation provider moves Virginia in the opposite direction.

A Services Facilitator is not simply someone who completes paperwork or performs an assessment. For many families, that person becomes a trusted and knowledgeable resource who understands the individual's needs, their attendants, their Employer of Record, their circumstances, and the challenges they face navigating an already complicated Medicaid system.

Those relationships take time to build.

Families should not be forced to give up a Services Facilitator they know and trust simply because Virginia has decided to restructure the program. If a family is satisfied with its current provider, is receiving appropriate services, and wants to continue that relationship, there should be a compelling reason before the Commonwealth takes that choice away.

I am particularly concerned about replacing a network of Services Facilitation providers with Support Brokers working through the Fiscal-Employer Agents. Consumer direction should mean more choices for individuals—not fewer.

If Virginia believes the Support Broker model can improve consumer-directed services, then give families the option to use it. Allow families to choose between qualified Services Facilitation providers and Support Brokers. If the new model truly provides better service, families can make that determination themselves.

Choice also creates accountability. When individuals have multiple qualified providers available, they have somewhere else to go if they receive poor service, cannot reach their facilitator, experience personality conflicts, or simply believe another provider would better meet their needs.

That is especially important for people with disabilities who depend upon these services for some of the most basic and important parts of daily life.

I also worry about what happens when the same larger system becomes responsible for more and more aspects of consumer-directed care. Families need someone who can help them navigate problems, ask questions, understand requirements, and advocate for the services the individual needs. Independence in that relationship has value.

Virginia should also consider the realities of rural communities. Families in rural areas already face limited access to many services and providers. A statewide or highly centralized system does not automatically mean better access. Local providers and facilitators may understand their communities, available resources, transportation challenges, caregiver shortages, and the individual families they serve in ways that cannot easily be replaced by a centralized system.

There is also a human side to this decision that should not be overlooked.

People receiving waiver services are not account numbers or cases. They are children, adults, seniors, and people with significant disabilities whose daily lives depend on these programs. Their parents, spouses, relatives, caregivers, and Employers of Record often spend enormous amounts of time coordinating their care and navigating Medicaid requirements.

When something in the system changes, these families are the ones who live with the consequences.

Before eliminating an established service, Virginia should be able to clearly demonstrate that the replacement will provide equal or better service, adequate staffing, reasonable caseloads, timely responses, continuity of care, knowledgeable support, and meaningful accountability.

Most importantly, Virginia should demonstrate why removing provider choice benefits the individual receiving services.

I support appropriate oversight and accountability for Medicaid services. If there are problems with particular Services Facilitation providers, address those problems. Strengthen standards. Improve training. Establish additional accountability measures. Remove providers that consistently fail to meet requirements.

But problems with individual providers should not require eliminating an entire model or taking choices away from every family in Virginia.

Improvement and consumer choice are not mutually exclusive.

Virginia can improve oversight while still allowing individuals to choose qualified providers.

Virginia can introduce Support Brokers without forcing every family to abandon its existing Services Facilitator.

Virginia can modernize consumer-directed services without making them less consumer-directed.

I respectfully ask DMAS and Virginia policymakers to preserve Services Facilitation as an option and protect the right of individuals and families to choose among qualified providers. At minimum, existing qualified Services Facilitators and Services Facilitation providers should have a meaningful pathway to continue serving the individuals and families who want to remain with them.

Please listen carefully to the people who actually use these services. They know what works in their homes. They know whom they trust. They know what kind of support they need.

A program called "consumer-directed" should begin with one fundamental principle:

The consumer should have a choice.

Please do not take that choice away.