Attn: Policy and Innovation Waiver Division / Public Comment Submission

Location: 600 E. Broad St., Suite 1300, Richmond, VA 23219

Statement of Purpose

We, the undersigned waiver participants, family members, caregivers, and

community advocates, formally petition and protest against the

proposed plan by the Virginia Department of Medical Assistance Services

(DMAS) to transition consumer-directed services into a centralized

broker system and phase out independent Service Facilitators (slated to

begin implementation in the Tidewater region on May 1, 2027).

Key Concerns and Demands

1. Protect Personalized, Community-Based Advocacy

Independent Service Facilitators serve as essential lifelines. They

know participants personally, understand unique medical and

daily living needs, and guide families through complex

bureaucratic processes. Replacing dedicated human advocates

with a centralized, corporate broker model strips away localized

trust and accountability.

2. Prevent Red Tape and Quality of Life Degradation

Transitioning to a corporate broker system creates administrative

barriers, limits individual oversight, and reduces vulnerable

participants to entries on a spreadsheet, risking severe service

disruptions and safety net degradation. 3. Uphold Consumer Choice and Autonomy

Dismantling a proven, choice-based network infringes upon the

core promise of consumer-directed care. Waiver recipients must

retain the right to select independent facilitators who directly

serve their interests.

4. Demand to Halt Overhaul

We demand that DMAS immediately halt the implementation of the

centralized broker system, preserve the role and independent

structure of Service Facilitators, and maintain the integrity of

Virginia’s innovation waiver programs.