I am writing to strongly oppose DMAS’s proposed 56-hour weekly cap on Consumer-Directed (CD) services and the elimination of Service Facilitation. These changes would significantly impact Virginia families, including my sister, who has cerebral palsy and requires extensive daily assistance to live safely and with dignity. She cannot walk, bathe herself, utilizes adult briefs and requires to be transferred and lifted through out the day, prepare meals, or drive. An eight-hour daily average is simply insufficient to meet her needs.
Our family lives in a rural area where finding and retaining dependable attendants is extremely difficult. We are not asking for 24/7 hour paid care; we are asking for reasonable support that allows individuals with disabilities to remain safe at home while recognizing the sacrifices family caregivers make, including lost employment opportunities and financial stability. Limiting paid hours does not eliminate the need for care—it shifts the burden onto families already stretched thin.
Having our father serve as her paid caregiver allows my sister to receive consistent care and remain in the home where she chooses to live, rather than potentially facing group home placement. There is also a financial consideration: why would Virginia risk paying thousands of dollars more monthly for residential care rather than compensate family caregivers approximately $13.88 per hour to help their loved ones remain home? DMAS should evaluate these potential costs before implementing changes that could result in more expensive care.
My sister’s needs also highlight the limitations of relying on day support services as an alternative to Consumer-Directed care. Cognitively, she is too high-functioning for the day support programs available to her, yet physically, she requires extensive assistance with nearly every aspect of daily living. This places her in a difficult position, as the available day support programs may primarily serve individuals with significantly different cognitive abilities and support needs. Placing her in such an environment would not appropriately meet her needs, promote her personal growth, or provide meaningful engagement suited to her abilities.
DMAS must recognize that individuals can be cognitively capable while physically dependent on others, and ensure that service policies account for both needs rather than assuming one type of support is appropriate for everyone.
I also strongly oppose eliminating Service Facilitation. Service Facilitators build relationships with families, understand their individual circumstances, and help them navigate complex program requirements. Given the existing administrative challenges families experience with CD payroll and paperwork through providers such as CDCN and PPL, eliminating Service Facilitation and transitioning these responsibilities to them would be catastrophic. Service Facilitators deserve to retain their jobs and the families they support.
If Virginia’s goal is to reduce unnecessary HCBS spending, DMAS should examine all service models fairly and consistently. Why are providers able to bill for group home or sponsored residential services, day support, and community engagement for the same individual in a single day—while families providing essential care through CD services face increased scrutiny? DMAS should ensure all services are necessary, appropriate, before disproportionately targeting family caregivers.
I respectfully urge DMAS to:
I understand Virginia may be facing financial pressures, but cost savings should not come at the expense of individuals with disabilities or the families who care for them. My sister is more than a number of authorized service hours. She deserves safety, dignity, and the right to remain in her own home. Our father’s role as her caregiver provides essential support, preserves her quality of life, and may prevent significantly higher residential care costs.
If cost reduction is truly the priority, all service models should be evaluated fairly—not just Consumer-Directed services and the families who depend on them. Please reconsider these proposals and protect the services that allow individuals with disabilities to live safely and with dignity in their communities.