I am submitting this comment as an active Services Facilitation provider and the owner of Miss Jada Meredith, LLC. I strongly oppose the proposal to eliminate independent Services Facilitation and replace it with Support Brokers operating through the Fiscal Employer Agents.

This proposal fails to consider how consumer-directed services actually function in the lives of members, families, Employers of Record, and attendants.

Public Partnerships, LLC and Consumer Direct Care Network already struggle to provide consistent, accurate, and timely assistance. Their representatives frequently lack sufficient knowledge of the Community Living, Family and Individual Supports, and CCC Plus Waivers. Families often receive conflicting information, experience long delays, or are transferred between representatives who do not understand the complete circumstances of the case.

These organizations currently perform fiscal and administrative functions. They are not presently equipped to provide the individualized coordination, assessment, education, advocacy, and problem-solving performed by Services Facilitators.

Services Facilitators serve as the essential connection among the member, family, Employer of Record, attendant, Fiscal Employer Agent, Managed Care Organization, Community Services Board, Department of Behavioral Health and Developmental Services, and Department of Medical Assistance Services. The consumer-directed model was built around this coordination.

Services Facilitators do far more than conduct visits and complete forms. We assist families with Plans of Care, service authorizations, attendant enrollment, payroll problems, Electronic Visit Verification issues, Medicaid eligibility concerns, income-verification requirements, policy changes, and communication among multiple agencies. When information is missing or incorrect, Services Facilitators identify the problem and coordinate its correction.

Services Facilitators work with these families every day, not merely during scheduled visits. Families contact us when an authorization is incorrect, an attendant cannot be enrolled, payroll is delayed, Medicaid eligibility is questioned, EVV is not functioning, or an urgent change occurs. We are often the first people families call because we know their circumstances and understand how the different parts of the system must work together.

Fiscal Employer Agents do not currently perform all these functions. If a family is already experiencing a problem with PPL or CDCN, placing the only Support Broker within that same organization removes the independent person the family presently relies upon to help resolve the problem.

Community Services Boards and DBHDS have important responsibilities within the Developmental Disability waiver system, but they are not staffed or structured to assume the full workload presently managed by independent Services Facilitators. Likewise, the MCO and DMAS structures serving CCC Plus members do not have the capacity to provide the same degree of individualized and responsive coordination to every consumer-directed household.

There is no evidence that these entities have the staffing, training, waiver-specific knowledge, caseload capacity, or operational infrastructure necessary to absorb this work statewide without serious disruption.

Without independent Services Facilitators, families may have no knowledgeable and accessible person to rely upon when something goes wrong. They may be forced to continue under a consumer-directed model without the support necessary to operate it successfully, resulting in delayed, reduced, or unavailable services. Alternatively, families may feel compelled to transfer to agency-directed care simply because they can no longer manage the administrative demands of consumer direction without assistance.

That outcome would not preserve consumer choice. It would effectively eliminate meaningful choice of service-delivery model by making consumer direction unworkable for many families. Members should not be pushed toward personal care agencies merely because Virginia removed the independent coordination that allowed them to direct their own care successfully.

These are not merely administrative transactions. These are people’s actual lives.

A delayed authorization can leave a person without care. An unresolved enrollment problem can prevent an attendant from working. A payroll failure can cause a family to lose a dependable caregiver. An eligibility or income-verification issue can jeopardize Medicaid coverage. A missed assessment or poorly developed Plan of Care can leave a medically fragile or disabled person without the services necessary to remain safely at home.

The realities of these situations are not adequately reflected in the proposal. The Commonwealth appears to be treating Services Facilitation as an unnecessary administrative layer when it is actually the coordination structure holding the consumer-directed model together.

Eliminating Services Facilitation without proving that another system can perform every existing function, at the necessary scale and level of responsiveness, would be a travesty. It would place members, families, and attendants at risk while dismantling the independent provider network that currently prevents countless service interruptions.

I respectfully request that DMAS withdraw the proposal to eliminate Services Facilitation. Virginia should address performance concerns through stronger standards, oversight, training, and enforcement rather than abolishing the service itself.

Consumer-directed services cannot function safely and effectively without knowledgeable, accessible, and independent coordination. Services Facilitators provide that coordination every day.