Protect Participant Choice, Trusted Relationships, and Existing Services Facilitation Providers

We submit this comment as a licensed organization providing agency-directed services and as a DMAS-enrolled Services Facilitation provider agency.

We recognize the Commonwealth’s responsibility to administer Medicaid efficiently. However, the proposed replacement of standalone Services Facilitation must address its impact on participants, their families, and the providers they rely on. The proposal needs explicit protections for participant continuity and a clear pathway for qualified existing SF agencies to continue serving.

1. How will participants’ choices and trusted relationships be protected?

Participants have distinct needs, preferences, routines, and goals. Familiar facilitators understand their communication styles, usual functioning, caregiver arrangements, and barriers to care. Established rapport helps participants discuss sensitive concerns and helps facilitators recognize changes that might otherwise go unnoticed.

Reassignment to an unfamiliar broker may cause anxiety, require families to repeatedly explain difficult circumstances, and delay disclosure or recognition of unmet needs. These concerns are particularly significant for individuals with cognitive impairments, communication disabilities, behavioral health needs, or limited informal support.

Will participants have an opportunity to retain their current qualified facilitator through the new model? How will their preferences be documented and considered?

DMAS should preserve existing relationships wherever feasible and consistent with participant choice. When reassignment is necessary, it should require a coordinated introduction, transfer of relevant information, and timely follow-up.

2. What safeguards will prevent gaps in support?

An authorization extension alone does not ensure that someone is available to address caregiver problems, changes in condition, or difficulty obtaining services.

Before existing SF arrangements end, will DMAS verify that a named broker has accepted responsibility, received essential records, and contacted the participant? Who will respond to urgent concerns before the first broker visit? What happens if the incoming contractor lacks sufficient staff?

Transition should depend on demonstrated readiness. Participants with urgent or complex needs should receive prioritized contact, and families should receive clear, accessible instructions about whom to call.

3. What pathway will existing SF agencies have to continue providing services?

The proposal does not clearly establish whether qualified, currently enrolled SF agencies may contract to provide support brokerage.

Will agency subcontracts be available? When will participation standards, application deadlines, selection criteria, payment terms, and procedures for reviewing contracting denials be published? Will organizations that also provide agency-directed care be eligible, and what conflict-of-interest safeguards will apply?

These questions directly affect whether experienced community providers can retain staff and remain available to participants. DMAS should establish an explicit, transparent agency participation pathway before existing SF arrangements are discontinued.

4. Will the transition preserve both experienced staff and agency capacity?

Individual employment opportunities and agency contracting opportunities are not interchangeable. Hiring an agency’s facilitators individually does not preserve the organization’s operating capacity, supervision, systems, or investment in service delivery.

Will existing SF training and experience be recognized toward broker qualifications? Have contract amendments been executed or recruitment begun? How will existing providers receive timely notice and a fair opportunity to participate?

Uncertainty threatens staff retention before the transition occurs. Clear written answers are necessary for responsible planning and continuity of services.

5. Where can participants obtain independent assistance?

When payroll administration and support brokerage operate through the same fiscal-employer agent, participants need a clear route outside that organization to resolve concerns.

DMAS should identify an independent escalation process, response deadlines, and accountability standards. Participants must be able to raise concerns about payroll, broker performance, or service access without uncertainty about where to turn.

Requested Revision

We request inclusion of the following language:

“DMAS shall require fiscal-employer agents to establish a transparent qualification and contracting process for existing Medicaid-enrolled services facilitation agencies in good standing to furnish support brokerage. The process shall include published participation standards, application timelines, reasonable payment terms, recognition of relevant workforce qualifications, and appropriate conflict-of-interest safeguards. Implementation shall document and consider participant preferences, preserve established facilitator relationships where feasible, and require coordinated handoffs and verified continuity of support before existing arrangements are terminated.”

Participants should not bear the burden of an administrative transition through disrupted relationships or difficulty obtaining assistance. Existing providers should not be left without clear information about whether and how they can continue serving.

We urge DMAS to provide written answers to these questions and establish enforceable participant protections and a defined provider participation pathway before implementation.