I urge those who are writing these changes to consider MacPac's Issue Brief of March 2022 "Advising Congress on Medicaid and CHIP Policy."  Please especially consider the following:

Paying family caregivers can be beneficial for the beneficiary and the state. This option allows many beneficiaries to select care that is culturally competent and in the language they speak. Paying family caregivers does not cost state Medicaid programs more, as these caregivers are providing care where a person would otherwise hire an unrelated independent provider (Teshale et al. 2021). Additionally, family caregivers can often provide more flexible hours than other providers. Historically, federal policy has restricted Medicaid’s ability to pay family caregivers due to concerns about isolation, caregiver burnout, and conflicts of interest. However, beneficiaries receiving care from paid family members have similar satisfaction with their care and similar community living outcomes to those receiving paid care from others (Edwards 2014).

This quote from MacPac addresses any real reasons DMAS might have for making these policies.  The policy changes are misguided and will only serve to hurt those with disabilities and their family caregivers.

The proposed changes, which severely limit a disabled individual's right to direct their own care, make absolutely no sense.  In 2011, the Department of Justice found that Virginia's policies and practices were in violation of the Americans with Disabilities Act.  Ten long years later, and Virginia has yet to fulfill all of the requirements of that agreement.  Why not focus on complying with the Americans with Disabilities Act before putting further restrictions on caregivers?