For point #1 - People receiving services through the DD waivers are often among the individuals with the most significant and complex support needs in Virginia's waiver system.  Many require extensive assistance with personal care, and health and safety monitoring.  For these individuals, a 56-hour weekly cap may not always be sufficient to meet their assessed needs.  In past rollouts, while it is said that exceptions will be considered on a case by case basis, providers don't find that to be true as the reviewers will cite the regulation without considering the exception to the rule.  Placing this cap could impact service delivery in a very negative way, making it exceedingly difficult to obtain an appropriate authorization.  

For point #2 - Service Facilitation has been criticized by many as hundreds of families have bravely voiced their experiences (or lack thereof) with service, saying things like, I cannot reach my facilitator, or I don't understand what they even do, or I tried to transfer and they won't issue a 225.  There have been a myriad of reports citing fraudulent signatures, a lack of visits being done that were billed for, or services abruptly ending without a transition plan.  There are inconsistent practices, limited or no monitoring, and a giant potential for waste, fraud, and abuse.  An ideal solution is to require services facilitation companies to become licensed agencies, or transferring members to licensed, highly regulated agencies that are already subject to comprehensive oversight, thereby increasing accountability and protecting public resources.  Licensed provider agencies operate under extensive oversight, including licensure requirements, quality assurance standards, incident reporting obligations, staff training requirements, routine audits, and regulatory compliance reviews.  By contrast, service facilitators do the same job, but without any of those guardrails or oversight in place, and with removing the degree requirement, they now don't even have appropriate education levels to be performing a function that requires a nurse in an agency.  Eliminating standalone service facilitation is absolutely the right call and will cut down on the rampant fraud that is running wild in the Commonwealth.