Strong Opposition to Service Facilitation Phase-Out / Support Broker Amendments (12 VAC 30-122
I am writing to express my deepest concern and strong opposition to the planned phase-out of standalone Service Facilitators and the transition to the Support Broker model under the Fiscal Employer Agent (FEA) contracts.
As a parent of a child who relies on the Developmental Disability (DD) Waiver, I know firsthand that this structural shift will be devastating for my son, for children with all types of disabilities, and for adults across the Commonwealth who depend on these services.
Raising a child with profound disabilities involves an immense, daily physical and emotional toll. Families like ours are already pushed to their limits just trying to navigate medical appointments, daily care, and specialized needs. Independent Service Facilitators have been our lifeline. They do not just handle paperwork—they serve as a trusted, accessible base of support. They make it possible for families to successfully navigate the complex web of available services, and they fight right alongside us to ensure our children receive the care they are legally entitled to.
Moving this vital responsibility into a centralized, bureaucratic brokerage system under state-contracted payroll agencies strips away independent, conflict-free advocacy. A Support Broker employed by a massive payment entity cannot replace the personal, dedicated check-and-balance system that an independent facilitator provides.
This decision isolates vulnerable families who are already overwhelmed. It removes the fierce, personalized advocacy that guards our children’s health, safety, and human rights. I urge DMAS and federal partners to halt this transition, protect standalone Service Facilitation, and preserve the independent advocacy network that our children desperately need to survive and thrive.
