69 comments
For point #1 - People receiving services through the DD waivers are often among the individuals with the most significant and complex support needs in Virginia's waiver system. Many require extensive assistance with personal care, and health and safety monitoring. For these individuals, a 56-hour weekly cap may not always be sufficient to meet their assessed needs. In past rollouts, while it is said that exceptions will be considered on a case by case basis, providers don't find that to be true as the reviewers will cite the regulation without considering the exception to the rule. Placing this cap could impact service delivery in a very negative way, making it exceedingly difficult to obtain an appropriate authorization.
For point #2 - Service Facilitation has been criticized by many as hundreds of families have bravely voiced their experiences (or lack thereof) with service, saying things like, I cannot reach my facilitator, or I don't understand what they even do, or I tried to transfer and they won't issue a 225. There have been a myriad of reports citing fraudulent signatures, a lack of visits being done that were billed for, or services abruptly ending without a transition plan. There are inconsistent practices, limited or no monitoring, and a giant potential for waste, fraud, and abuse. An ideal solution is to require services facilitation companies to become licensed agencies, or transferring members to licensed, highly regulated agencies that are already subject to comprehensive oversight, thereby increasing accountability and protecting public resources. Licensed provider agencies operate under extensive oversight, including licensure requirements, quality assurance standards, incident reporting obligations, staff training requirements, routine audits, and regulatory compliance reviews. By contrast, service facilitators do the same job, but without any of those guardrails or oversight in place, and with removing the degree requirement, they now don't even have appropriate education levels to be performing a function that requires a nurse in an agency. Eliminating standalone service facilitation is absolutely the right call and will cut down on the rampant fraud that is running wild in the Commonwealth.
Hello,
I have worked in the health insurance industry for over 15 years and recently had to transition to a caregiver roll for my last surviving parent. I am alone with no support and my services facilitator, who is knowledgeable, helpful and fully dedicated to her patients, has been the only reason I’ve been able to maintain my own sanity and get things done.
I know all too well how MCO’s operate. Members are NOT people they are dollar signs. Any and every opportunity to deny a service and save them $1 happens every time and allowing them to take over facilitating these services is a near death sentence to everyone who is like me, fixed to care for a failing family member because there are no other options.
handling more control over to the insurance companies sends a clear message, you and your loved ones are not important only the money is. I will work and advocate to remove any public official who votes or supports this despicable proposed change. There must be a time when PEOPLE are valued more than money and that time must be NOW.
I appreciate that the cap is described as ‘soft’ and that exceptions are available. But a weekly limit is still concerning if families must prove extraordinary need to preserve hours that are already necessary for a child’s safety, health, personal care, communication, mobility, behavior support, and inclusion in community life. Many children with Down syndrome have needs that vary greatly from one child to another, and those needs cannot be safely captured by a one-size-fits-all number.
I urge DMAS to revise or clarify several provisions to ensure that children with Down syndrome and other developmental disabilities do not lose individualized, medically necessary supports.
First, I am concerned about implementation of a 56-hour weekly “soft cap” on personal care/assistance in the Community Living and Family and Individual Supports waivers. Children with Down syndrome have highly individualized needs. Some need extensive assistance with activities of daily living, supervision for safety, communication support, mobility assistance, feeding, medical needs, or support related to co-occurring conditions. A weekly benchmark should never operate as a de facto cap or create an assumption that care above 56 hours is unusual or unjustified.
DMAS should ensure that exceptions above 56 hours are available through a simple, timely, and child-centered process; are decided before existing hours are reduced; are based on functional need and risk of institutionalization rather than diagnosis alone; and include clear written decisions and meaningful appeal rights. Families should not experience gaps in services while an exception request or appeal is under review.
Second, DMAS should protect continuity of consumer-directed services during the transition from standalone services facilitation to the statewide service-broker model. Families need a readily accessible, knowledgeable contact who can help with hiring, payroll, authorizations, training, and problem-solving. The transition should not interrupt care, reduce family choice, or make it harder to retain dependable workers.
Third, any changes to Employer of Record rules should preserve appropriate safeguards for minors and individuals who cannot independently direct care. Parents, guardians, and authorized representatives must be able to carry out necessary employer responsibilities without unnecessary administrative barriers.
Finally, I ask DMAS to reconsider removal of legally responsible persons as providers of Employment and Community Transportation, or at minimum establish a meaningful exception when no safe, accessible, and reliable alternative is available. Transportation is often essential to community participation, therapy, health care, employment preparation, and family stability. Removing legally responsible persons as allowable providers of Employment and Community Transportation may be troubling where a parent is the only practical, trained, reliable person able to transport a child safely, particularly in rural areas, for medical appointments, therapies, jobs, volunteer activities, or community programs.
Virginia’s waivers should remain genuinely person-centered: services should be determined by each child’s assessed needs and family circumstances, not by an administrative limit that may not reflect the realities of care at home.
Protect Participant Choice, Trusted Relationships, and Existing Services Facilitation Providers
We submit this comment as a licensed organization providing agency-directed services and as a DMAS-enrolled Services Facilitation provider agency.
We recognize the Commonwealth’s responsibility to administer Medicaid efficiently. However, the proposed replacement of standalone Services Facilitation must address its impact on participants, their families, and the providers they rely on. The proposal needs explicit protections for participant continuity and a clear pathway for qualified existing SF agencies to continue serving.
1. How will participants’ choices and trusted relationships be protected?
Participants have distinct needs, preferences, routines, and goals. Familiar facilitators understand their communication styles, usual functioning, caregiver arrangements, and barriers to care. Established rapport helps participants discuss sensitive concerns and helps facilitators recognize changes that might otherwise go unnoticed.
Reassignment to an unfamiliar broker may cause anxiety, require families to repeatedly explain difficult circumstances, and delay disclosure or recognition of unmet needs. These concerns are particularly significant for individuals with cognitive impairments, communication disabilities, behavioral health needs, or limited informal support.
Will participants have an opportunity to retain their current qualified facilitator through the new model? How will their preferences be documented and considered?
DMAS should preserve existing relationships wherever feasible and consistent with participant choice. When reassignment is necessary, it should require a coordinated introduction, transfer of relevant information, and timely follow-up.
2. What safeguards will prevent gaps in support?
An authorization extension alone does not ensure that someone is available to address caregiver problems, changes in condition, or difficulty obtaining services.
Before existing SF arrangements end, will DMAS verify that a named broker has accepted responsibility, received essential records, and contacted the participant? Who will respond to urgent concerns before the first broker visit? What happens if the incoming contractor lacks sufficient staff?
Transition should depend on demonstrated readiness. Participants with urgent or complex needs should receive prioritized contact, and families should receive clear, accessible instructions about whom to call.
3. What pathway will existing SF agencies have to continue providing services?
The proposal does not clearly establish whether qualified, currently enrolled SF agencies may contract to provide support brokerage.
Will agency subcontracts be available? When will participation standards, application deadlines, selection criteria, payment terms, and procedures for reviewing contracting denials be published? Will organizations that also provide agency-directed care be eligible, and what conflict-of-interest safeguards will apply?
These questions directly affect whether experienced community providers can retain staff and remain available to participants. DMAS should establish an explicit, transparent agency participation pathway before existing SF arrangements are discontinued.
4. Will the transition preserve both experienced staff and agency capacity?
Individual employment opportunities and agency contracting opportunities are not interchangeable. Hiring an agency’s facilitators individually does not preserve the organization’s operating capacity, supervision, systems, or investment in service delivery.
Will existing SF training and experience be recognized toward broker qualifications? Have contract amendments been executed or recruitment begun? How will existing providers receive timely notice and a fair opportunity to participate?
Uncertainty threatens staff retention before the transition occurs. Clear written answers are necessary for responsible planning and continuity of services.
5. Where can participants obtain independent assistance?
When payroll administration and support brokerage operate through the same fiscal-employer agent, participants need a clear route outside that organization to resolve concerns.
DMAS should identify an independent escalation process, response deadlines, and accountability standards. Participants must be able to raise concerns about payroll, broker performance, or service access without uncertainty about where to turn.
Requested Revision
We request inclusion of the following language:
“DMAS shall require fiscal-employer agents to establish a transparent qualification and contracting process for existing Medicaid-enrolled services facilitation agencies in good standing to furnish support brokerage. The process shall include published participation standards, application timelines, reasonable payment terms, recognition of relevant workforce qualifications, and appropriate conflict-of-interest safeguards. Implementation shall document and consider participant preferences, preserve established facilitator relationships where feasible, and require coordinated handoffs and verified continuity of support before existing arrangements are terminated.”
Participants should not bear the burden of an administrative transition through disrupted relationships or difficulty obtaining assistance. Existing providers should not be left without clear information about whether and how they can continue serving.
We urge DMAS to provide written answers to these questions and establish enforceable participant protections and a defined provider participation pathway before implementation.
I am writing as a family member of an individual who receives Medicaid waiver services and who has personally experienced the positive impact that Services Facilitation has on families like mine.
I strongly oppose eliminating Services Facilitation as a standalone service and replacing the current model with a statewide Support Broker model.
A Services Facilitator is not simply someone who completes paperwork or conducts required visits. For many families, our Services Facilitator becomes one of the few people within this complicated system who truly understands our loved one's needs, daily challenges, care requirements, and history. They help families understand Medicaid requirements, navigate consumer-directed services, address problems, obtain necessary documentation, and advocate when services are threatened.
That advocacy is incredibly important.
When an insurance company or managed care organization proposes reducing a loved one's personal care hours, the people making that decision often do not see what happens inside the home every day. They do not see the assistance required with bathing, dressing, eating, toileting, mobility, behaviors, safety, supervision, elopement risks, or the many other needs that families manage around the clock.
Services Facilitators see the bigger picture. They know the individual and family. They can identify what information is missing, explain what documentation may be needed, help families understand their options, and guide them through an extremely difficult system when services are reduced, denied, or questioned.
Removing this relationship risks removing an important layer of advocacy and continuity from consumer-directed services.
Families in the disability community already spend enormous amounts of time navigating Medicaid, managed care organizations, authorizations, assessments, appeals, schools, medical appointments, caregiving, and countless administrative requirements. We should be strengthening the people who help families successfully navigate these systems not removing them.
I am also deeply concerned about what happens when families are moved into a centralized statewide model. How will DMAS ensure that Support Brokers have manageable caseloads? How quickly will families receive assistance when an urgent problem occurs? Will families have consistent contact with the same person who knows their loved one's history? Who will help a parent understand their options when personal care hours are suddenly reduced? Who will notice when an assessment does not accurately reflect what is actually happening inside the home?
These questions need clear answers before Virginia dismantles a system that many families currently depend upon.
Efficiency and administrative restructuring should never come at the expense of individualized support. People with disabilities are not files, authorization numbers, or cases. They are human beings whose ability to remain safely in their homes and communities often depends upon having knowledgeable people helping their families navigate an extraordinarily complicated system.
It is deeply unjust that major administrative changes so often place the greatest burden on individuals with disabilities and the families caring for them.
I urge DMAS and CMS to reconsider eliminating Services Facilitation as a standalone service. At minimum, Virginia should preserve meaningful choice and continuity by allowing families who have established, successful relationships with qualified Services Facilitators to continue receiving that support, or ensure that existing experienced Services Facilitators have a meaningful role in whatever system replaces it.
Please listen to the families who actually use these services. Decisions about disability services should not be made solely based on administrative efficiency. They should be evaluated based on what protects individuals, supports families, preserves independence, and allows people with disabilities to remain safely in their homes and communities.
Services Facilitators have made a positive difference in our lives. Please do not remove a support that is working for families like mine.
I strongly oppose eliminating the services facilitation model and replacing it with the broker model.. Having experienced services facilitation model and how it lightened the heavy load of administrative paperwork that family caregivers are often unfamiliar with only leads a logical person to the conclusion of fully supporting the services facilitation model.
Services facilitators have advocated for my family member throughout the years by being keenly aware of their individual needs and disabilities and communicated them to Medicaid and MCOs. They didn't view my family member as a number.
The services facilitation model shouldn't be dismantled, it should be strengthened.
The information being provided states that Support Brokers will be hired through the Fiscal/Employer Agents.
If there is a way for an existing Services Facilitator or established Services Facilitation company to contract with PPL, CDCN or another entity as a Support Broker provider, please make that opportunity known to us.
Please explain what the qualifications will be, what the contracting requirements will be and whether our existing businesses will have an opportunity to participate.
If there is no contracting pathway and Support Brokers will only be able to work as employees of the Fiscal/Employer Agents, then I respectfully ask DMAS to make that clear as well.
Existing providers need enough information and enough time to make responsible decisions.
For some of us, this is much bigger than simply having to find another job.
There are Services Facilitation companies that have hired and trained multiple employees to go into the field and serve Medicaid members. Those businesses now face the possibility of losing experienced staff and dismantling operations that were built specifically to serve Virginia’s consumer-directed population.
Those employees have learned this program. They have developed relationships with individuals and families. They understand the documentation, the responsibilities of consumer direction and the challenges that can occur within the system.
I would hate to see that experience simply disappear.
There are also real financial obligations involved.
Existing providers have made substantial investments in order to operate properly.
Many of us have entered into contracts for HIPAA-compliant systems, electronic documentation and recordkeeping platforms, software services and other systems necessary to operate our businesses appropriately and protect the information entrusted to us.
Some of those contractual obligations extend three years or more into the future.
We have paid for business insurance, credentialing, technology, training and other operational expenses because we wanted to follow proper protocol and meet the standards expected of Virginia Medicaid providers.
Those were not unnecessary business expenses.
They were investments made in good faith for the betterment and protection of our clients, our staff and our businesses.
We made long-term decisions based upon the program Virginia established and the requirements we were expected to follow.
That is why it is difficult not to feel let down.
After approximately 21 years in this field, I have continued adapting every time the program changed. I have invested in my business, invested in compliance and technology, trained staff, entered into contracts necessary to operate responsibly, and through all of it, continued serving Virginia Medicaid members.
Now I am faced with the possibility that the service my business was built around may simply no longer exist.
I am not asking that programs never change.
I am asking Virginia to consider the people who have spent years doing what Virginia asked us to do—and, even more importantly, the individuals and families who depend on us.
If there is a reasonable way for experienced and qualified Services Facilitators and established Services Facilitation companies to transition into contracted Support Broker roles, please give us that opportunity and make the pathway known.
Doing so could preserve experienced professionals while also preserving something incredibly important for the individuals receiving services: continuity of relationships and meaningful choice.
After 21 years, I have accumulated a tremendous amount of knowledge about consumer-directed services. There are many other Services Facilitators throughout Virginia who bring that same experience and dedication to this program.
I hope that knowledge is not simply lost.
There are real people behind these changes.
There are individuals with disabilities and older Virginians who rely on these services to remain in their homes and communities. There are families trying to navigate a complicated Medicaid system. There are attendants providing their daily care. There are employees whose livelihoods may be affected. And there are small business owners who have invested years of their lives into providing these services.
But above everything else, there are individuals who deserve to remain at the center of consumer direction.
I sincerely hope DMAS will consider whether the new model preserves their ability to choose who supports them, whether they will continue to have access to someone who can help advocate and mediate when problems occur, and whether the relationships they have spent years developing with trusted Services Facilitators truly need to be lost in order for Virginia to move to a Support Broker model.
I have genuinely tried throughout my career to represent what I believe Virginia Medicaid’s Services Facilitation program should be. I have tried to serve people well, do things correctly and be someone individuals and families can call when they need help.
Twenty-one years is a significant portion of my working life.
I simply hope there is a place for that experience, for the other experienced providers across Virginia, and most importantly, for the relationships we have built with the individuals and families we serve in whatever Virginia builds next.
1. Service Facilitators provide valuable, person-facing service/expertise representing people with disabilities that cannot be done over the phone with a different random person every month. It is near impossible to get CDCN/PPL on the phone today, much less adding Service Facilitation functions like annual attendant care hour renewal paperwork. Those renewals happen as a natural course of knowing our families, which is not possible through a CDCN/PPL switchboard. I cannot imagine the phone waits if this is done -- it is simply not tenable. Do not do this.
2. Oppose ending DMAS higher level review in cases where persons on the CCC+ waiver are later found ineligible. One person's opinion in a 10-min visit should not singly eliminate services enabling a person with disabilities to function in society and maintain independent living. Attendant care is a lifeline for families of persons with disabilities, and it should not be removed without careful due diligence. Attendant care is significantly cheaper to taxpayers than institutionalization, which is often the only option when attendant care is eliminated and families cannot make ends meet financially and also provide 24/7 care to their loved ones.
Public Comment Regarding Proposed CCC+ Waiver Amendment
Service Facilitation / Statewide Service Broker Model
I am the parent and Employer of Record for a young child with significant medical needs who receives consumer-directed personal care through the CCC+ Waiver. I am commenting specifically on the proposal to incorporate Services Facilitation into the statewide service broker model through the Fiscal Employer Agent and eliminate Services Facilitation as a standalone service.
I understand the potential benefit of simplifying the consumer-directed system. However, I ask DMAS to make sure that this transition does not remove an important layer of individualized assistance and advocacy for families caring for medically complex children.
Our family has recently experienced firsthand how administrative issues involving the Service Facilitator, Fiscal Employer Agent, authorization information, enrollment paperwork, background checks, time entry, and payroll can delay access to services or payment even when the underlying personal care services have been authorized.
For families caring for individuals with significant disabilities and medical needs, these are not simply paperwork inconveniences. An administrative breakdown can affect whether an attendant can begin working, whether authorized hours can be entered, and whether a caregiver is paid for services that were actually provided.
Before eliminating standalone Services Facilitation, I respectfully ask DMAS to ensure that the new statewide service broker model includes:
1. A clearly identified individual or team responsible for helping families resolve enrollment, authorization, EVV, payroll, and Fiscal Employer Agent problems.
2. Clear escalation procedures when an administrative or system problem prevents an attendant from working, entering authorized time, or being paid.
3. Continuity protections so that families do not lose authorized services because information, forms, authorizations, background checks, or other records fail to transfer correctly between organizations or systems.
4. A process for correcting administrative errors without requiring families to repeatedly contact multiple entities to determine which organization is responsible.
5. Appropriate accommodations and individualized assistance for families of medically complex children and individuals whose disabilities make navigating consumer-directed administrative requirements especially difficult.
6. Clear written information before implementation explaining exactly which responsibilities currently performed by Service Facilitators will transfer to the service broker, which will transfer to the Fiscal Employer Agent, and who families should contact when something goes wrong.
I also encourage DMAS to obtain meaningful input from families currently using consumer-directed services before finalizing the transition procedures. Families and attendants experience parts of this system that may not be apparent from administrative data alone.
Consumer direction can allow individuals with significant disabilities to remain safely at home with people who understand their unique care needs. Administrative modernization should strengthen that model, not unintentionally create new barriers to receiving already-authorized care.
Thank you for considering the experiences of families who depend on the CCC+ Waiver.
the issue wiht this is our facilitators know our kids and needs , placing someone in this position without knowing or understanding situations is crazy. Like my daughter she does not get along with strangers or be around them. It took Danielle months before our daughter would even look at her let alone let her speak to her. Now you want to change this??
I understand the need to save money but this is not where to do it nor capping hours to 56
please come stay in my home for 2 weeks see if you can do what we do daily
Regards
Robert and Katie Church
Please stop Virginia from regressing back to the worst Eugenic State of the Union! Oppose Eliminating Service Facilitators and Oppose Ending DMAS Higher Level Review
1. Service Facilitators are protective government oversight that are not monetarily incentivized (unlike Capitalist for shareholder private insurance companies) and provide person-facing service/expertise representing people with disabilities that cannot be done over the phone with a different random person every month.
It is designed to be nearly inaccessible (by design because these are for profit companies trying to up the shareholder cost share profits) to reach CDCN/PPL on the phone today, much less adding Service Facilitation functions like annual attendant care hour renewal paperwork. Those renewals happen as a natural course of knowing our families, which is not possible through a CDCN/PPL switchboard. I too cannot fathom the phone waits if this is done -- it is simply not tenable. This will destroy care and is destruction.
2. Strongly Oppose ending DMAS higher level review in cases where persons on the CCC+ waiver are later found ineligible. This is protective government oversight (the government has a constitutional obligation to protect vulnerable and disabled citizens and that is one of the reasons we have local, state, and federal taxes- to protect the citizens: NOT give tax dollars to greedy private for profit shareholders corporate profits that take government tax dollars and give below legal minimum to fatten their shareholder profits (none of the private insurance companies nor private equity companies are B-corporations which is the only somewhat ethically not exploitive capitalist business model) so we cannot destroy the government oversight that keeps greedy profit chasers from breaking laws (none oversight =no checks and balances) and cutting hours so whatever broker gets a bonus that month from cutting hours and making more profit for ABC Private Insurance Company.
One person's opinion in a 10-min visit should not singly eliminate services enabling a person with disabilities to function in society and maintain independent living.
Attendant care is a lifeline for families of persons with disabilities, and it should not be removed without careful due diligence. Attendant care is significantly cheaper to taxpayers than institutionalization, which is often the only option when attendant care is eliminated and families cannot make ends meet financially and also provide 24/7 care to their loved ones.
Virginia tax dollars should pay for local Virginia care attendants to give care for Virginia disabled citizens in their Virginia homes or Virginia residential care homes custom to their choice.
Virginia home and community care should be strengthened and expanded, not continually decimated for the profits of mostly out of state based corporate entities planning to push disabled out of more affordable to the taxpayers home and community care into institutions that once home and community care is decimated, these institutions will jack inflate prices to 3-5x the cost of home and community care it destroyed.
Virginia has a horrific history of being amongst the worst eugenics driven states in the history of the United States- and these cuts and destruction of government oversight and home care supports are eugenic- the same forces that once drove disabled folks into institutions to be sterilized, experimented on, and left to die faster to less humane and healthy conditions: these forces are at work NOW. These forces want to steal community support tax dollars and push disabled into lower and more fatal institutional life for profit.
Every oversight cut suggestion
Every destruction of support hours in home and community- that is a eugenic push to exploit disabled into for profit institutions because there will be no other choices left.
If you vote for private insurance companies to take over protective government oversight reviews- you are signing death warrants and giving disabled people’s community access hours support: trading their community supports and transportation time to INSTITUTIONAL PRISON TIME for being disabled and having needs.
Many people can be supported at home far cheaper than in at least 3x cost of hospital or institution: by having care attendant hours I have saved both her private and Medicaid insurance companies thousands by doing her at home oxygen and respiratory therapy exercises at home where she is comfortable and has family who loves her- me doing her care hour is hundreds cheaper than in hospital or institution— one of many examples.
You cannot put soft caps at 56 hours ethically or if you have some semblance of a compassionate heart- many at home caregivers cannot work 24/7 and not crash out- more than 56 hours is regular and affordable vs hospital or institution yet you have greedy people lobbying greedy politicians seeking re-election whispering “blame the parents for fraud , blame the non-profit social worker case managers for inflating hours” when statistically the numbers couldn’t even come close to matching the TRUE FRAUD of Private insurance companies and private equity firms COMMITTING MASSIVE LARGE SCALE FRAUD beyond anything individuals could rack up.
The DOJ once found Virginia so grossly negligent that it demanded it course correct for its systemic discrimination and unnecessary institutionalization of disabled citizens- other states became more humane and grew home and community care- Virginia was greedy and segregating disabled with a Jim Crow zest and neglect. Olmstead is still LAW till the law falls no matter what executive branch declares. Until the Judicial Branch overturns Olmstead- Olmstead HOLDS.
These cuts VIOLATE Olmstead - they devastate disabled people and their families, and they are evil and genocidal because more disabled people die in the institutions these cuts want to lock disabled people into- so these cuts of oversight and care caps are a slow method of disabled genocide because they target disabled people, many of whom are not legally capable of defending themselves- the government should protect rather than imprison them.
Please stop eugenics NOW.
All SF are not created equal. The complaints are valid and limited to a small number of big agencies that have lost credibility and trust with families because of poor customer service and staffing issues. Those of us who genuinely care and provide good service and advocacy have developed relationships with our families and earned their trust. What will happen to us? SFs stand alone to bridge the gap between MCO and Fiscal Agent; we are advocates. We see our individuals more than any other provider, and we are invested in their well-being. I oppose this transition UNLESS it allows current providers to
1. continue to operate autonomously under our own name and reputation
2. retain our caseload and our staff
3. receive the same or increased compensation for our time
4. the process is streamlined and does not disrupt service authorization renewals
I strongly oppose eliminating service facilitation and replacing it with a support broker model. Our service facilitators know our children, understand their individual needs, and have taken the time to build trust with our families. That relationship is extremely important and cannot simply be replaced by assigning someone new who may not know or understand our child’s situation.
I understand that there is a need to control costs and use resources responsibly, but eliminating a service that families depend on and capping hours at 56 is not the place to make those cuts. The people making these decisions need to understand what families are actually dealing with day to day.
It is difficult to make decisions like this without fully understanding what it is like to raise and care for a child with a disability. Families are already managing challenges every single day that most people never have to think about. Replacing an experienced facilitator with someone who doesn’t know our child is a major step backwards. It risks disrupting relationships that took months or even years to build and could reduce the quality of life not only for our children, but for the families caring for them.
Please reconsider these changes and listen to the families who live with these realities every single day.
My parents, grandparents, siblings, husband, extended family, and me have all worked for, and paid taxes to, the state of Virginia for decades. Never have any of us ever asked for anything from the state until years after the birth of my son.
Upon his birth I was no longer able to work since he required 24 hour care. Even then I did not ask for anything from the state. We managed with what insurance offered, sporadic nursing, and taking on full responsibility for our son ourselves. Since I could not return to work, my husband worked 3 jobs to support us and did so for over 20 years. We never asked for a dime from Virginia.
Now my son is an adult, I find myself managing him alone and did seek guidance and help from the state on my son's behalf.
His needs have become more extensive over the years, and I became his live-in caregiver. It took months of meetings and paperwork and hoops to jump through to get help to begin with, and now the same people who helped me are also losing their jobs. That's incredulous!
Virginia will take away the Service Facilitators, who we chose, who helped guide us through the DMAS maze and who advocates for us, forcing us to use to use a "Broker" of Virginia's choosing not our own, employed by the fiscal agent who pays us. Isn't that a conflict of interest?
Virginia also wants to cap our hours. Well, my hours are 24/7 regardless of what Virginia feels is justified in paying for. Why not have Virginia cap the DMAS workers hours, but expect them to continue working unpaid to help these disabled persons, how many would do so? Even for an hour? Probably no one. Yet parents do it day after day year after year.
I have one question, what would Virginia do if all the parents caring for their adult children, become so overwhelmed with the system and the lack of resources, that we lift our hands in defeat and we put our children in the state of Virginia's care? We walk away?
Where would you house these disabled adults? What agency would care for them? Who would you then have to train and pay to care for our family members? Would you send them to group homes? You would never have enough homes for them all. Foster care is not an option, they are too old.
I'm sure using the families homes and vehicles is incredibly less expensive than having to maintain group home properties, staff them, provide transportation and so on. What would the state do if all the parents walked away? Have you considered this?
You have advocates in the parents and family member caregivers of these disabled adults. Help us help them and in turn help Virginia. Use our expertise in these complex issues our kids face to better Virginia's care, raise awareness, work on good alternatives for these struggling adults. Provide us with the resources we need!
These special adults need compassion as do the exhausted faithful families who care for them, to the point of giving up our own dreams, freedoms and careers to care for our families in need. Put yourself in our shoes. Don't be a state that shamefully turns it's back those who need you the most.
Help us!
JMM
I'm not sure what level of incredulousness I am looking at here. You want to remove Service Facilitators and use Support Brokers that are employed by CDCN or PPL. I can't believe I'm typing that sentence. Do any of you have disabled loved ones at home that you take care of 24/7? If you're here, then I would say you don't, unless you're lucky enough to have someone step in for you. Have you ever had to directly deal with CDCN or PPL? I and my husband both have. They are horrible at customer service. Their response time (if they give one) is horrible. Their attitudes are horrible. And with them hiring and training these support brokers, I would bet they don't know what they're supposed to be doing.
The service facilitators I've dealt with have been amazing. They're on time, they attentive, they have great personalities. They know exactly what they should be doing and how to advocate for their patients. A lot of them have given their entire lives to providing this type of help to patients and they love what they do. You putting them out of business by adding these support brokers is foolishness. The amount of money you think they will save is nothing compared to the amount of trouble they will bring. And the title of "Support Broker" is so cold. I'm not an investment for someone to make money off of. I'm a patient, someone that needs care because she cannot do things for herself. I became disabled in early 2022. This has been an immense help to me. I'm not sure where I would be without it. It was a service facilitator that helped me settle in and get accustomed to this.
You cannot just remove the people we've come to know and are familiar with our lives and situations for these new brokers. It would absolutely do more harm than good.
Oppose the support of brokers. Service Facilitation is a necessity and consumer directed care would not be consumer directed without them. Consumers should be able to choose.
Dear Virginia,
There is no easy way to care for people with disabilities. After 25 years, I know the time, effort and care that it takes to keep our child safe and well cared for. I don't understand why VA refuses to see the need for family support. Do we need to go back to the institutions our state was forced to close by the DOJ? That's what will happen if families can't easily get the support they desperately need.
As far as brokers, we are totally against them. Our local Service Facilitators know us and care about our needs. We have options if one service doesn't work out, there are others to choose from. Put them all under the state and we're stuck with lousy service and no options. Don't mess with what works in our county.
My family has lived, worked, and paid taxes in the Commonwealth of Virginia for decades. During that time, we have asked very little of the state. For most of my life, my parents, extended family, and I managed the care of my disabled twin siblings on our own, relying on what insurance would cover, limited nursing support when available, and our own resources to meet needs that were not otherwise addressed.
After my mother passed away, someone had to provide full-time care for my wheelchair-bound siblings. Because their needs required care twenty-four hours a day, seven days a week, I was no longer able to continue working in the profession I had chosen. We could not find suitable caregivers who were willing or able to use the specialized equipment required to care for them safely, and the liability concerns made reliable outside care extremely difficult to secure.
Even during my childhood, our family did not seek extraordinary services from the state. We paid for home modifications, including ramps, accessible bathrooms, and vehicle adaptations for wheelchairs. We often struggled financially, including making house payments, while still trying to remain within income restrictions so my siblings would not lose Medicaid eligibility. If my father earned too much, our family was penalized. Despite these challenges, we continued to shoulder the responsibility ourselves.
My mother has since passed away, as has my disabled sister. My brother is now an adult, my father is aging, and I find myself managing my brother’s care largely on my own while seeking guidance and support from the state on his behalf.
Over the years, my brother’s needs have become more extensive. My parents and I built a home specifically designed to meet those needs because there was no realistic alternative, including a nursing facility, that could provide the level of continuous care he requires. For families in this position, proposed reductions or caps on care hours are deeply concerning.
I am especially concerned about proposals that would remove the Service Facilitators we have chosen and relied upon. These facilitators help families navigate the DMAS system, understand requirements, and advocate for the individuals receiving care. Replacing them with a broker selected by the state and employed through the fiscal agent raises serious concerns about independence, accountability, and potential conflicts of interest.
I am also concerned about any effort to cap care hours. My caregiving responsibilities do not end when the approved hours end. My brother requires support around the clock, regardless of what the state determines is compensable. Families continue providing care day after day, year after year, often without rest, because there is no one else to do it.
I ask the Commonwealth to consider what would happen if families like mine became so overwhelmed by the system, the lack of resources, and additional administrative burdens that we could no longer continue. I have cared for my brother for eleven years and cared for my sister for seven years before her passing. I am exhausted and burned out, yet new requirements and reduced supports would only make an already difficult situation harder.
If families were forced to step back, where would these disabled adults live? Which agency would assume responsibility for their daily care? Who would be trained and paid to provide the complex support they require? Would the state place them in group homes, and if so, would those homes have appropriate wheelchair accessibility, lifts, transfer equipment, accessible bathrooms, and specialized transportation? Many of these individuals cannot use ordinary transportation and require costly modified vehicles or paid medical transportation. The current system depends heavily on family homes, family vehicles, and unpaid or underpaid family labor.
It seems clear that supporting families in their homes is far less costly and more humane than creating and maintaining enough residential placements, staffing them around the clock, purchasing specialized equipment, and providing transportation for every individual who could no longer remain with family. The state should carefully consider the consequences if parents and siblings are pushed past the point of being able to continue.
Families are not obstacles in this process; we are advocates, caregivers, and partners. We have firsthand expertise in the complex daily realities of caring for disabled adults with significant needs. Virginia should use that expertise to improve care, strengthen resources, raise awareness, and develop realistic alternatives that support both individuals with disabilities and the families who care for them.
These adults deserve compassion, dignity, and consistent care. Their families deserve compassion as well. Many of us have given up careers, financial stability, personal freedom, and long-held dreams in order to care for loved ones who cannot safely care for themselves. I respectfully ask Virginia not to turn away from the people who need support the most.
Please help us continue helping them. Provide families with the resources, flexibility, and respect needed to keep our loved ones safe, supported, and cared for in the most appropriate setting possible.
Stephanie Whitmer sibling to John S. Whitmer
It will be a night mare! The will not be able to advocate on behalf of consumers nor be able to address call. As it stands now, they are not able to handle calls.
Please keep service facilitator services they go above and beyond on the work they provide to us caregivers. Why strip that away? Why stop something that doesn't need to be fixed.
I strongly oppose eliminating Service Facilitation and replacing it with support brokers employed through the Fiscal-Employer Agent.
The person who is disabled must be the center of this decision. That person depends on consumer-directed care to eat, bathe, use the bathroom, take medication, remain safe, and continue living at home. When the system fails, that person—not DMAS, a fiscal agent, or another contractor—lives with the consequences.
I am the mother of an adult daughter who is nonverbal and completely dependent on others for her care. She cannot explain her needs to an unfamiliar broker or tell that person when something is wrong. Her trusted Service Facilitator--whom she chose--knows how she communicates, understands her history, recognizes changes, and knows the realities of her daily life. That knowledge develops through time and trust. It cannot simply be transferred in a file.
Virginia’s current regulation, 12VAC30-122-500, requires Service Facilitation to be available by telephone during business hours, provide help when requested, and be offered “on an as-needed basis as mutually agreed to” by the person, EOR, and Service Facilitator. The proposed model identifies no enforceable response time, caseload limit, continuity requirement, or guarantee that the person will consistently have access to someone who knows them.
Consumer-directed care is being hollowed out. The name remains while the person’s directive authority continues to shrink. More decisions are being transferred to the state, an app, or a contractor. The person remains responsible for complying with every rule and bears the consequences when something fails, yet has less meaningful control over the people and structure governing their care. If the person can no longer choose an independent Service Facilitator, what exactly is left for the “consumer” to direct?
Virginia has defended EVV as necessary for accountability and fraud prevention. Yet this proposal would remove an independent human safeguard—a professional who enters the home, knows the person, and can recognize what an electronic record cannot. An app can record a time and location. It cannot determine whether a person who is disabled is safe, understood, treated with dignity, or properly cared for.
This is not merely an administrative transition. It will end trusted relationships, reduce meaningful choice, and move Virginia further away from genuinely person-directed care.
Keep Service Facilitation as an independent waiver service. Do not continue taking authority away from the very people “consumer-directed” care is supposed to empower.
My family previously used consumer-directed services, and our experience with Services Facilitation was very positive. Our facilitator was knowledgeable, independent, accessible, and genuinely helpful in making consumer direction work.
I have read many of the comments already submitted, and others have raised important questions about continuity, consumer choice, broker qualifications, caseloads, and the relationship between Support Brokers and the Fiscal-Employer Agents. Rather than repeat those concerns, I want to ask what I think is the most basic question.
What problem with the existing Services Facilitation model is this change intended to solve, and what evidence does DMAS have that the proposed Support Broker model will produce better outcomes for Medicaid members?
This should not be answered simply by describing how the new system will operate. The question is why the change is necessary in the first place.
Services Facilitation was not perfect, and experiences undoubtedly varied. But in our case, it worked. Before eliminating a service that has worked well for many individuals and families, DMAS should be able to explain clearly what is wrong with the present model, what evidence supports replacing it, and how the person receiving Medicaid services will be better off afterward.
That is ultimately the measure that matters. Not whether the new administrative structure is cleaner or easier to manage, but whether it improves the life and experience of the person receiving the service.
Stop allowing these changes with no prior communication, no detailed plan roll out, and coming from people who do not live this daily! Highly advising against brokers! This is not what the people want. This is not a structure that is built for success, this is a structure that puts DMAS first- NOT the families ! Taking away their ability to chose within CD model is absolutely against everything the model stood for. Choice. Person centered. HEAR the SFs when they tell you this is not what they want either!!!
I strongly oppose the proposal to eliminate Services Facilitation and replace it entirely with the Support Broker model.
I have worked within Services Facilitation for many years, and I have seen firsthand how important this service is to individuals receiving consumer-directed services, their families, Employers of Record, and attendants. Services Facilitation is much more than completing an assessment or conducting a required visit. Service Facilitators build relationships with families, educate EORs on their responsibilities, identify changes in an individual's needs, assist with service authorizations, address problems before they become interruptions in care, and help families navigate an extremely complicated Medicaid system.
My concern is not simply that the title of the position is changing. My concern is that Virginia is proposing to dismantle an established statewide network of experienced Services Facilitators without providing enough information to demonstrate that the replacement system will have the workforce, capacity, training, experience, accessibility, and infrastructure necessary to serve every consumer-directed individual in Virginia without disruption.
Under the proposal, Support Brokers would be employed through the Fiscal-Employer Agents, CDCN or PPL, and Services Facilitation would ultimately cease to exist. Before such a significant change is implemented, families and stakeholders deserve much more information.
How many Support Brokers will be required statewide? How will enough qualified Support Brokers be recruited and trained before each regional transition? What caseload sizes will Support Brokers carry? What experience and qualifications will be required? How will continuity be maintained for individuals with complex medical, behavioral, developmental, or communication needs? What happens when a Support Broker position is vacant? How quickly will families receive assistance when an authorization issue threatens someone's care? Will families have any meaningful choice regarding who provides this support?
These questions should be answered before Virginia eliminates an existing service.
I am also deeply concerned about losing established relationships. Many Service Facilitators have worked with the same individuals and families for years. They know the individual's history, needs, caregivers, attendants, challenges, and preferences. For vulnerable individuals receiving Medicaid waiver services, continuity and trust matter. Replacing a familiar Service Facilitator simply because a geographic transition date has arrived may create unnecessary disruption for the very people this system is intended to support.
Consumer direction is supposed to empower individuals and families. Any redesign should strengthen that principle, not reduce choice or remove trusted supports without demonstrating that the replacement will provide equal or better access and assistance.
I understand that systems can evolve and that there may be opportunities to improve consumer-directed services. However, improvement does not require eliminating the experience, knowledge, relationships, and infrastructure that already exist within Services Facilitation.
I urge DMAS to reconsider eliminating Services Facilitation. At minimum, Virginia should consider a model that allows qualified existing Services Facilitation providers and experienced Service Facilitators to participate in the Support Broker system, preserves meaningful consumer choice, establishes clear workforce and caseload standards, and demonstrates adequate statewide capacity before terminating the current service.
A transition of this magnitude should not move forward based only on a timeline. It should move forward only when Virginia can demonstrate that individuals will not lose access, continuity, choice, or the knowledgeable support they currently receive.
The individuals and families who rely on consumer-directed services deserve a transition built around their needs—not simply an administrative restructuring of how those supports are delivered.
Please preserve Services Facilitation or establish a transition model that meaningfully incorporates the experienced providers and Service Facilitators who have been serving Virginia's families for years.
Service Facilitators have become largely ineffective. Hopefully ‘The Broker’
system has been tried and tested to prevent people from falling off Waivers
when S.F.s become unreliable. The Disabled Go With Out Services, being
cut off suddenly when S.F.s disappear because they are not well-trained.
The Savings From the Elimination of S.F. should go directly to waiver recipients/care
providers and Direct Support Personnel.
May this not be ‘a good idea on paper’ for which systems and staffing
is NOT prepared to deliver. You are NOT using the Immigrant Contractors
Caught working as CSBs AND DMAS double-dipping are you?
I am writing as the Legally Responsible Individual (LRI) for my 14-year-old niece, who relies on the Commonwealth Coordinated Care (CCC) Plus Waiver to manage Lennox-Gastaut Syndrome, complex seizure clusters, and profound daily care needs. I strongly oppose the proposed elimination of standalone, independent Services Facilitation agencies in Virginia.
Our current Services Facilitator is uniquely qualified because they possess a comprehensive, multi-generational scope of expertise—successfully supporting clients ranging all the way from toddlers to grandparents. Phasing out localized, versatile Services Facilitators and replacing them with a distant, centralized statewide "Support Broker" creates severe operational hazards for families like ours for the following critical reasons:
* Loss of Specialized, Adaptive Advocacy: A centralized state contractor cannot replicate the deep, hyper-local knowledge that an independent agency provides. Our facilitator understands the entire lifespan of care, allowing them to provide nuanced insights that protect my niece as she grows. A centralized state broker will inevitably become a bureaucratic bottleneck.
* Compounding Administrative Burnout: As an LRI, my primary focus must remain on direct, life-sustaining clinical oversight—including managing intricate multi-medication schedules, VNS implants, and unpredictable, long-lasting seizure clusters. Forcing families into a rigid, centralized system right alongside the stressful rollout of new Electronic Visit Verification (EVV) tracking rules and the CareAttend app creates an unsustainable administrative burden.
* Erosion of Consumer Choice: The core philosophy of consumer-directed waivers is choice. Stripping families of the right to choose an independent agency that aligns with their unique household dynamics directly contradicts the intent of Medicaid home and community-based services.
Centralizing this system under a single state umbrella will not improve care monitoring; it will isolate vulnerable families, remove essential checks and balances, and destabilize the local networks we rely on to keep our loved ones safe at home. I urge DMAS and the General Assembly to halt this transition and maintain standalone, independent Services Facilitation.
Describe the nature and relationship of ‘Support Brokers’…
Because Public Consulting Group has been a Massive
Disaster. Just saw training materials leaked that discuss how
to Employ DEI in services and lock White People Out. Recent Professional
Development Presentation. Let’s not practice Eugenics in VA.
So, How Many Beds/Rooms Across VA are available for the Massive influx
of Waiver Recipients for whom the new limitations will make
In-Home Care Impossible? Always Taking FROM The Truly Disabled.
Just when things kind of are stable, another massive change, but overall,
Service Facilitators continue to miss the mark, like MULTIPLE No-Shows holding up
Annual Renewals, like it is planned for people to go without services/pay until
the last possible second, inflicting harm, damages, and since Covid families have
adjusted to the in-home care model, because, before, during and after COVID, there
is and has been a MASSIVE shortage of quality in-home care providers and direct support persons.
If all EIN beneficiaries have been eliminated as ineligible,
I truly hope accuracy and flexibility and access to Agency
Directed Care Services will greatly improve for American Citizens.
A ‘soft cap’ is a direct signal of potential illegality.
Have there been deep independent investigations or independent
audits? Our Disabled Populations are experiencing severe hardships
with utilities alone skyrocketing into the stratosphere.
I oppose removing managed-care organizations from reviewing CCC+ service plans without establishing an equally independent and accountable replacement.
I am also deeply concerned about the combined effect of this proposal and the separate proposal to eliminate Services Facilitators. Services Facilitators frequently become advocates and problem-solvers for individuals and families. They help families understand complicated rules, address problems with fiscal agents and service authorizations, correct errors, and push back when the system is not working properly.
Families already struggle to navigate Medicaid requirements and protect authorized services. Removing existing levels of review and eliminating Services Facilitators would take away important layers of security between families and the organizations responsible for administering, authorizing, and paying for services.
Transferring these responsibilities to Support Brokers employed through the fiscal-employer agents creates a legitimate concern about independence and possible conflicts of interest. Families need someone whose primary responsibility is protecting the participant’s interests—not someone connected to an organization that also manages administrative requirements, payroll, or other program functions.
When independent advocacy and higher-level reviews are removed, I fear that errors will go unchallenged, service reductions will become easier, and families will have fewer people available to help prevent the loss of necessary benefits.
Before making these changes, DMAS must explain:
Virginia should strengthen independent advocacy and oversight for waiver participants—not remove existing safeguards and concentrate additional authority within the same organizations. No change should be implemented unless families retain access to a genuinely independent person who can advocate for the participant, identify errors, challenge inappropriate reductions, and help protect essential services.
Support Removing an additional link in already overly-complicated
model of service provision and delivery. With 3 severely disabled
children by choice as an adoptive Mom, I do a lot of work ‘for’ and
spend a lot of time with Service Facilitators when I could be
providing care instead. Monthly meetings are not too long, but
3 different ones for kids with different waivers/varied ages plus
annual long visits, then VIDES/ISPs, occasional SIS, Healthcare Firm
Case Management and etc. I do FAR more Paperwork and Administration even
WITH service facilitation that is is brutal and downright nearly abusive.
To someone else’s comment with cuts to service delivery hours even though
though I’m ALWAYS ‘On Call’ 24-7, is Virginia prepared to pay the price and provide the
care requirements and needs when there is a mass ‘revolt’ by people who just
Can’t take on anymore? The children QUALIFY for Long-Term Care, which is NOT
limited to 56/hrs. week.
Thank You for the opportunity to share stark reality.
Christina York
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?
I strongly oppose imposing a 56-hour weekly cap on personal assistance without clear, accessible, and enforceable protections for individuals whose documented needs exceed 56 hours.
I am the mother and caregiver of two children with significant developmental disabilities. My son receives the Family and Individual Supports Waiver and is currently authorized for more then 56 hours of personal assistance each week. He has profound communication limitations and requires extensive assistance with activities of daily living and safety due to elopement, PICA, seizures, self-injurious and aggressive behaviors, and an inability to recognize danger. Reducing him from 56 hours would remove hours of necessary assistance every week. His needs will not decrease simply because the state establishes a numerical limit
My daughter receives the Community Living Waiver. She previously received several more hours but was reduced to exactly 56 hours during her May 1, 2026 renewal in which she needs all the extensive assistance as my son. That experience makes me extremely concerned about how a so-called “soft cap” may function in practice.
Before implementing this amendment, DMAS must clearly explain:
Any exception process must be based upon the individual’s assessed needs and health and safety—not budgetary pressure or an arbitrary weekly number. No existing hours should be reduced until the individual receives proper notice, an individualized assessment, an opportunity to provide supporting information, and access to all applicable appeal rights.
I support correcting inaccurate form references and removing obsolete language from the requirements governing paid Legally Responsible Individuals. However, DMAS must ensure that this technical correction is not used to create new restrictions, additional paperwork, payment delays, or barriers for qualified family caregivers.
Families need a clear written explanation of exactly what is changing and what is remaining the same. DMAS should confirm that currently enrolled and approved Legally Responsible Individuals will not be required to repeat enrollment unnecessarily and that attendants will continue to be paid while records or enrollment documents are updated.
Paid family caregivers often provide essential assistance when no qualified outside workers are available. Any revised language must preserve individualized determinations, recognize extraordinary care needs, and provide reasonable time and direct assistance to correct documentation.
EORs do mostly the work of a SF without a way to access a computer
with programs for input. The movement over time of SF responsibility to
EORs is a great reason to move to a broker-type of arrangement.
EORs - For YEARS however have been UNPAID ‘Voluntary’ Positions
with Great Amounts of DEMANDS and REQUIREMENTS.
Lonnie Smitherman
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.