I strongly oppose the proposed elimination of independent Services Facilitation and believe the current proposal has not been sufficiently thought through from the perspective of the individuals and families who actually rely on consumer-directed services.
My greatest concern is this: Who will help families between quarterly visits?
Services Facilitation is so much more than completing an assessment or conducting a required visit. A strong Service Facilitation organization becomes part of the support system that allows families to successfully navigate an incredibly complicated Medicaid system.
The organization does not simply send a Service Facilitator to a home and disappear until the next required visit. The one we use have built an entire infrastructure around supporting individuals with disabilities and their families. Just look at their social media... their newsletters!!!!
They stay informed about Medicaid and waiver changes and translate those changes into information families can actually understand, breaking it down to help people. REPLYING TO QUESTIONS AT ALL HOURS ON THEIR FACEBOOK!!!! They develop partnerships with disability organizations and community resources across Virginia so families like mine can be connected with help beyond the waiver.
They help families understand the waiver system, including where to begin when they are trying to apply for a waiver. They have team members dedicated to helping families understand processes, paperwork, Medicaid requirements, and where they need to go next. MY FAMILY WAS ONE OF THOSE FAMILIES!!!!!
Moms in motion also has an entire team dedicated specifically to helping families resolve problems involving Fiscal Employer Agents. That exists because families already experience situations where they need additional assistance navigating these systems. They troubleshoot issues, help families understand what is happening, and help connect them with the right people when something goes wrong. Who will do this when SF's are gone!?!?!
So I believe an important question must be answered before Services Facilitation is eliminated:
If families already need this level of assistance while they have an independent Service Facilitator advocating alongside them, what happens when that independent support is removed and the Support Broker is employed through the Fiscal Employer Agent itself?
Who helps a family when they cannot resolve an issue with the Fiscal Employer Agent?
Who helps them understand a new requirement?
Who tells them when attendant pay rates change and explains what that means?
Who helps them understand paid sick leave?
Who explains what a Designated Representative is?
Who helps a new Employer of Record understand what they are actually responsible for? (because believe me one visit every 3 months DOES NOT GET THIS DONE!!!)
Who gets on a video call with a confused family and walks through a problem with them?
Who recognizes that a family does not even know the right question to ask?!?!?!?!?!?!
And most importantly, who is available during the months between quarterly visits when something goes wrong?
Consumer direction places significant responsibility on individuals, families, and Employers of Record. They hire and manage attendants, navigate Fiscal Employer Agent systems, comply with Medicaid requirements, respond to policy changes, manage documentation, and try to understand a system that even experienced professionals can find complicated.
Removing independent Services Facilitation does not remove those responsibilities. It risks removing one of the primary resources families currently have to help them carry those responsibilities successfully.
I understand that the proposed Support Broker model includes quarterly visits and assessments. But a quarterly visit is not the same thing as ongoing accessibility, education, troubleshooting, advocacy, and relationship-based support.
I am also deeply concerned about placing Support Brokers under the Fiscal Employer Agents. Independence matters. Families should have somewhere to turn when they are experiencing problems with the very entity responsible for fiscal-employer functions. Removing the independent Service Facilitator risks eliminating an important layer of assistance and accountability from the consumer-directed model.
Before Virginia dismantles the existing Services Facilitation system, there should be a clear, detailed answer explaining who will perform all of these functions, how families will access that assistance between quarterly visits, what response-time standards will exist, how families will receive education about policy changes, and who will independently advocate for them when problems involve the Fiscal Employer Agent.
Consumer direction is supposed to empower individuals and families. YOU should be strengthening the infrastructure that helps them successfully direct their own services—not reducing the independent support surrounding them. AND TAKING AWAY THEIR PROVIDER CHOICE!
Please reconsider the elimination of independent Services Facilitation.
The question should not simply be whether another entity can conduct the required quarterly visit.
The question should be:
Who will be there for the family during all the days in between, do they care about the families the way that their SF does, AND are they knowledgeable to provide the service and all the added benefits we gained from our SF and all their support staff?