I urge you think about all these things before implementing these horrible actions.

Do you have a family member with a waiver? Or are you someone with a waiver? You very likely are not, and I urge you to truly put yourself in some else’s shoes.
Have you personally surprise visited institutions, facilities and nursing house throughout the state? I have. They are overrun, understaffed and many times negligent with or without intention. These regulations will absolutely increase institutionalization, which is the whole reason why these waivers exist… To avoid institutionalization.
Have you spoken with agencies across the state? Do they have the proper staff? Heck no. Do they have staff to take on an influx of clients that will occur with these changes? Are they enough agencies throughout the state? Can they drive clients(children and adults) to their appointments. I have never been able to find an agency that drives children, which is why my sons lost their waivers years ago because I knew CD services existed. I also want to point out that it looks very suspicious for Virginia, who already ranks at the bottom in the county for services for those with disabilities, and who has already had wayyyy too many civic rights violation complaint… for Virginia to now essentially have agencies now run consumer directed services, that looks like some deep pocket kickback stuff. There’s a consumer directed model, and then there’s an agency directed model for the already known purpose. You are now having agencies, which I have a lot of fraud already going on, getting paid for customer directed services. Just because there is no EOR, does NOT mean that a parent or spouse feeding to go through an agency is not still essentially consumer directed. It’s just controlled by an agency now.
I urge you to really think about what is best for these individuals and please do your due diligence because a lot of harm is about to come to families and individuals with disabilities and it can be avoided with properly educating and investigating. Because then you will see the harm these regulations will cause to the most vulnerable population… people you are supposed to serve and protect.