I am the parent of an adult who is a recipient of the DD Waiver and I am writing regarding the proposed changes.

• Brokers replacing Service Facilitators. It is concerning that brokers will be contracted by the Fiscal Agent, who will now have numerous contracts with the state and will be highly incentivized to hold onto them. These brokers will be representing the states interests, not the consumers and that will be reflected in the plan of care and the services/hours that they think the consumer should receive. How is it better for all Virginians to shut down smaller, local companies in order to make the FA, who are huge companies, the middle man, who will siphon off more money for themselves. When these brokers don't process the paperwork in a timely manner and families lose attendants and money, what recourse will we have when you have removed all choice. We will be stuck with a company that has a monopoly over the whole system.
• 56 Hour Cap. The reality is that many individuals who receive the DD Waiver need assistance with all their IADLS's and ADL's. That is why they qualify. So to then turn around and say that they only need 56 hours of care is completely illogical. It will lead to unsafe situations for many adults and a higher risk of institutionalization. As those of us who walk this path know, the paperwork to receive an exception will be so complex that many will not even attempt it or will give up. This being done to mirror other waivers doesn't make sense. All the waivers are different and have different eligibility criteria. Why have separate waivers if they all provide the same hours?
• EVV for Live in Carers. The very nature of being a live in care giver makes this difficult. Many will forget to log in and therefore won't get paid for those shifts or forget to log out and be penalized, resulting in them losing the ability to be a carer. Also, it is hard to know how the system will round out the hours, I logged 36 minutes on the app and it logged as 45 minutes in the portal. This is going to lead to attendants either being out of compliance because they don't know how the hours will transfer to the portal or they will start logging out early to avoid being non compliant, resulting in the state not having to pay the full amount of hours allocated. The fact that we have to log into a portal, which we are not allowed to use, to check that actual hours allocated for the shift is ironic. The inability to correct shifts without being penalized and threatened is disturbing, the state would rather people recorded incorrect shifts out of fear of repercussions. It is hard to comprehend why this is being pushed for so hard.

All these changes shift more of a burden onto families and the people who don't have families will be forced into institutions. How you reconcile the massive cost of that I have no idea. It is hard to understand how an agency can have so little understanding of the daily lives of the people with which it is tasked with serving.