As a Certified Work Incentive Benefits Counselor practicing in Virginia, a former Medicaid waiver recipient, and a Personal Assistance Services caregiver, I submit this comment from both professional and lived experience.

My position on the proposed transition from Services Facilitation to a Support Brokerage model is mixed. I will be direct: the current model is not working as it should. When I was on the waiver, my Services Facilitator routinely submitted plans of care that were incorrect, and it was my support coordinator who caught and corrected the errors. A redundant layer without accountability helps no one, and I do not oppose reform.

My concern is with where the power lands. Placing Support Brokers inside the Fiscal-Employer Agent — the same entity that handles payroll and taxes — creates a structural conflict of interest. CDCN and PPL should not control the pipeline that determines how many hours of care a person receives. The entity managing the money should not also shape the decisions about how much care is authorized; those decisions determine whether people can live safely in their homes.

I also want to address capacity directly. In my experience, neither PPL nor CDCN is handling the responsibilities they have right now very well. Adding more stress to an already cracked system could be disastrous.

My recommendation is to shift authorization responsibility toward the support coordinator. In my experience, the support coordinator was the one who made sure the plan of care was actually accurate. Support coordinators remain in place under this proposal, already know the individuals they serve, and already function as the backstop when facilitation fails. Strengthening their formal role in the authorization process would answer the oversight concerns behind this proposal without handing hour determinations to the fiscal agent.

I urge DMAS to separate brokerage and administrative functions from authorization decisions, and to formalize the support coordinator's role in verifying plans of care before hours are approved.

Respectfully,

Elizabeth Whitehead Jennings