The individuals most affected by these changes are also among the least likely to submit comments themselves. Many rely on family members, Support Coordinators, Services Facilitators, or other trusted supports to identify problems, explain changes, and advocate when something goes wrong. Those are the same individuals who will bear the consequences if the proposed broker system is difficult to navigate or fails to function as intended.

Virginia’s HCBS waivers exist to help people with disabilities remain safely in their homes and communities. Any major change to that system should be judged by one question: Will this make it easier or harder for the individual to receive the support they need to remain safely in their community?

According to The Governor's Proposed 2026-28 Budget, these changes are projected to produce substantial reduction in Medicaid spending. The 56-hour limit on personal care and assistance is projected to save $43.9 million in FY2027 and $49.6 million in FY2028, while replacing standalone Services Facilitation with the statewide Support Broker model is projected to save another $4.3 million in FY2027 and $4.5 million in FY2028. Together, those two changes are projected to reduce Medicaid spending by approximately $102.3 million over two years. It would eliminate, by the budget's own admission on page 82 of the Health and Human Resources section of the proposed budget, a support that “provides information and assists the member and their family/primary caregivers with learning the responsibilities of a consumer directed employer of record.” A 56-hour limit, even a soft limit, creates a new threshold that individuals whose needs exceed it must overcome to retain the level of care they have been assessed as needing.

For many people receiving waiver services, continuity is not a convenience. Replacing a provider can mean losing years of accumulated knowledge about a person’s routines, communication, behavior, warning signs, and the supports that make daily life possible.

Virginia’s recent transition from Modivcare to MTM shows how quickly a statewide administrative change can become a service problem when communication does not keep pace with implementation. Individuals, families, providers, and local professionals reported learning of the change only after the transition occurred. Communication has remained inconsistent: MTM began coordinating FFS transportation on October 1, yet as of October 6, some DMAS webpages still identify Modivcare as the statewide FFS transportation broker and direct members to Modivcare, while others identify MTM as the current broker.

The Support Broker transition carries greater consequences because it reaches directly into the assessment and delivery of care. An error in an assessment, Plan of Care, authorization, or attendant process can become a reduction in needed support, a delay in care, or an interruption serious enough to threaten the person’s ability to remain safely at home.

Will this make it easier or harder for the individual to receive the support they need to remain safely in their community? The fiscal wellness of Viginia should not be carried by those least able to advocate for their own care.