It is extremely concerning that the removal of educational requirements is being considered for service facilitators. Service facilitation is already a nightmare of a service for clients, their families, and community services board support coordinators. There is already an extreme lack of oversight for service facilitators. Support Coordinators have constant issues with service facilitators not being responsive to problems and concerns. The Service facilitators often refuse to help problem-solve issues that they should be addressing. They write quarterly reports that consist of inaccurate information, and that are typically copied and pasted from previous reports. They don't provide any ounce of oversight to the services being carried out by the paid attendants. They tend to refuse to assist clients with the finding and hiring of attendants, even with things as simple as the enrollment paperwork for the attendants. They put everything on the clients, their families, and/or the CSB support coordinators. Many support coordinators are very confused as to what they actually are responsible for, due to the long list of things that they refuse to do and won't engage in. I am a support coordinator for a CSB. Every single client that we have receiving services through a service facilitator says that they have not seen anyone from their service facilitation agency in months, and in some cases, over a year. Meanwhile, the SF agency has an active service authorization and is billing for the client as far as we are aware. When authorizations are pended, SF agencies don't tend to know what to do to correct the pends. This often results in a lapse in services for the client. We have support coordinators who have never received quarterly reports from SF agencies for clients that have been in services with the SF's for years. There is no one holding them responsible for submitting quarterly reports to the CSB support coordinators. Support Coordinators at the CSB's are given all of the responsibility for overseeing the SF's, but there is no power given to the SC's to do anything about the constant issues. The only glimmer of hope that SC's have when it comes to SF agencies is that they are being held to at least some sort of standard at the state and governmental levels. By taking away things like educational requirements, you're eliminating one of the only parameters that it appears the SF agencies have. This will continue to cause the services that are provided by SF agencies to become unusable and inoperable. The disabled population in Virginia deserves better quality services offered by SF agencies. I highly encourage you to refrain from taking this action and instead, reach out to CSB's and request feedback from their support coordinators first. The SC's are the "boots on the ground" that have the direct experience and knowledge of how the SF agencies aren't sufficient and why. I can promise you that you will receive ample justification as to why SF agencies need more oversight and parameters, not less.