I strongly oppose the proposal to eliminate the current Service Facilitation model and transfer these responsibilities to Support Brokers associated with the existing fiscal agents.

I am a Service Facilitator working directly with individuals receiving consumer-directed waiver services and their families. From that experience, I believe this proposal significantly underestimates both the role Service Facilitators currently perform and the importance of the relationships we develop with the people we serve.

Service Facilitation is not simply a periodic visit or administrative requirement.

We become a consistent point of contact for individuals, Employers of Record, families, and attendants. We answer questions about consumer-directed services, help families understand requirements, identify problems before they result in interruptions of care, assist with authorization issues, and coordinate with other entities involved in the individual's services.

We know our clients.

We know their diagnoses, functional limitations, caregivers, attendants, authorized services, and individual circumstances. Those relationships are developed over repeated contact and cannot simply be replaced by transferring a list of responsibilities from one organization to another.

I am particularly concerned about consolidating Service Facilitation responsibilities with the fiscal agents. Fiscal agents already have substantial responsibilities related to payroll and administration of consumer-directed services. In my professional experience, clients and families already report difficulty reaching fiscal-agent representatives and resolving payroll and administrative issues in a timely manner.

The proposed model would add Support Broker responsibilities, quarterly in-home visits, service authorization responsibilities, and ongoing consumer assistance to organizations that must simultaneously continue performing their existing fiscal responsibilities.

DMAS should carefully consider what happens when all of these responsibilities are concentrated within the same organizations.

Service Facilitators currently provide another layer of oversight and advocacy within the consumer-directed system. When there is a problem involving an attendant, authorization, fiscal agent, managed care organization, or another part of the system, families have an independent Service Facilitator who can help identify the issue and work toward a resolution.

Under the proposed model, families would lose that independent resource.

The proposal also significantly reduces consumer choice. Individuals currently have the ability to select among Service Facilitation providers and change providers when a company does not meet their needs. That choice creates accountability and allows individuals to select an organization whose approach best fits their circumstances.

Replacing that system with a choice between only two Support Broker organizations—organizations that also serve as the fiscal agents—substantially limits that freedom.

That is especially concerning within a program built around the principle of consumer direction.

There is also a practical capacity question that deserves serious consideration: How will two organizations absorb the number of individuals currently served by Service Facilitation providers across Virginia, conduct required in-home visits, manage authorizations, provide knowledgeable and timely support, and continue administering their existing fiscal responsibilities without sacrificing accessibility or quality?

Before dismantling the current Service Facilitation system, DMAS should be able to demonstrate that the replacement model will provide equal or better responsiveness, continuity, consumer choice, accountability, and protection against interruptions in services.

The consequences of failure will not simply be administrative. They will be experienced by children and adults with disabilities, older Virginians, caregivers, and families who depend on these services every day.

I urge DMAS to reconsider this proposal, preserve independent Service Facilitation, and include Service Facilitators, individuals receiving services, Employers of Record, attendants, and families in any meaningful effort to improve Virginia's consumer-directed service system.

Service Facilitation should be strengthened where improvement is needed—not eliminated.