I strongly oppose the proposal to eliminate Services Facilitation and replace it entirely with the Support Broker model.

I have worked within Services Facilitation for many years, and I have seen firsthand how important this service is to individuals receiving consumer-directed services, their families, Employers of Record, and attendants. Services Facilitation is much more than completing an assessment or conducting a required visit. Service Facilitators build relationships with families, educate EORs on their responsibilities, identify changes in an individual's needs, assist with service authorizations, address problems before they become interruptions in care, and help families navigate an extremely complicated Medicaid system.

My concern is not simply that the title of the position is changing. My concern is that Virginia is proposing to dismantle an established statewide network of experienced Services Facilitators without providing enough information to demonstrate that the replacement system will have the workforce, capacity, training, experience, accessibility, and infrastructure necessary to serve every consumer-directed individual in Virginia without disruption.

Under the proposal, Support Brokers would be employed through the Fiscal-Employer Agents, CDCN or PPL, and Services Facilitation would ultimately cease to exist. Before such a significant change is implemented, families and stakeholders deserve much more information.

How many Support Brokers will be required statewide? How will enough qualified Support Brokers be recruited and trained before each regional transition? What caseload sizes will Support Brokers carry? What experience and qualifications will be required? How will continuity be maintained for individuals with complex medical, behavioral, developmental, or communication needs? What happens when a Support Broker position is vacant? How quickly will families receive assistance when an authorization issue threatens someone's care? Will families have any meaningful choice regarding who provides this support?

These questions should be answered before Virginia eliminates an existing service.

I am also deeply concerned about losing established relationships. Many Service Facilitators have worked with the same individuals and families for years. They know the individual's history, needs, caregivers, attendants, challenges, and preferences. For vulnerable individuals receiving Medicaid waiver services, continuity and trust matter. Replacing a familiar Service Facilitator simply because a geographic transition date has arrived may create unnecessary disruption for the very people this system is intended to support.

Consumer direction is supposed to empower individuals and families. Any redesign should strengthen that principle, not reduce choice or remove trusted supports without demonstrating that the replacement will provide equal or better access and assistance.

I understand that systems can evolve and that there may be opportunities to improve consumer-directed services. However, improvement does not require eliminating the experience, knowledge, relationships, and infrastructure that already exist within Services Facilitation.

I urge DMAS to reconsider eliminating Services Facilitation. At minimum, Virginia should consider a model that allows qualified existing Services Facilitation providers and experienced Service Facilitators to participate in the Support Broker system, preserves meaningful consumer choice, establishes clear workforce and caseload standards, and demonstrates adequate statewide capacity before terminating the current service.

A transition of this magnitude should not move forward based only on a timeline. It should move forward only when Virginia can demonstrate that individuals will not lose access, continuity, choice, or the knowledgeable support they currently receive.

The individuals and families who rely on consumer-directed services deserve a transition built around their needs—not simply an administrative restructuring of how those supports are delivered.

Please preserve Services Facilitation or establish a transition model that meaningfully incorporates the experienced providers and Service Facilitators who have been serving Virginia's families for years.