The Support Broker model has several problems.

First, removing independent services facilitators (SFs) removes the ability to freely choose them when a SF doesn't work out for an individual/family. Under the broker model, folks would be stuck with SFs under the fiscal employer agent (FE/A) and not able to switch to another company. People should have access to a market of different SFs when a company is not working well with or for them.

Second, I don't have any trust that FE/As will be adequate at service facilitation. Considering the track record of companies like PPL and CDCN, they have terrible customer service and technology for users. They push the responsibilities of correcting issues (like logging shifts accurately) onto the EOR or caregivers when their apps glitch. Their system often malfunctions and my caregivers and I have had to complain about PPL withholding wages from my caregivers due to issues that were not the result of the actions of either caregiver or care recipient. I just submitted another complaint to DMAS since PPL made shifts disappear from their portal in what may be an illegal manipulation of caregiver shift data. PPL has also been investigated for fraud in NY, which doesn't elicit trust in them. Lots of SFs will refuse to work with CDCN and PPL which will result in a loss of institutional knowledge with which FE/As will need to cope. I see this functioning as well as Molina did as an MCO here in Virginia, which was terrible and why they didn't have their contract renewed with DMAS.

Third, some changes that DMAS is looking to make with aligning some of the DD waiver and CCC Plus policy can be achieved through SFs and don't require a broker model to make it happen. As long as the regs and policy are changed, SFs have to follow it. The broker model isn't necessary to achieve this end.

Fourth, the state can also achieve greater support for EORs by passing on the planned "coaching" responsibility to SFs through related regs and policies. Paying the SFs for this work in the current model is just as feasible as paying the the FE/As in the broker model. Creating a new model doesn't benefit waiver and personal care recipients any more than having SFs do the same. And, it won't cost money and time to create a new model and would avoid the problems I address in this comment.

Fifth, SFs may lose their jobs and many individuals and families will lose their SF with whom they have a great relationship. It will also lead to a loss of proper accounting for the needs of the individual that new and inexperienced support brokers under the new model will not be able to account for. Keeping the experienced SFs in the field leads to better service provided to members.

Sixth, and perhaps most importantly, there is no tangible benefit for members and caregivers. This is especially the case if DMAS puts some EOR responsibilities on SFs instead of using the broker model. As an EOR myself, I don't see how the broker model would work better or more efficiently.