Thank you for the opportunity to comment on the proposed transition from Services Facilitation to a Support Broker model.  I am speaking from the perspective of a community based provider with direct experience helping individuals with disabilities and their families navigate consumer-directed services.   I strongly support the current model and service of Services Facilitation in the Commonwealth.  I believe Services Facilitation and quality facilitators have made positive impacts in the lives of individuals with disabilities.  I believe they have been the advocates that have ensured that community life remains an option for many individuals.  I believe they have provided countless unbillable hours of service assisting families and individuals navigate complex systems, address challenges within the program of waiver services, and connect individuals to valuable community resources. 

If the Commonwealth moves forward with the proposal to remove Services Facilitation as a service and move to a Support Broker model I have some questions and thoughts I would like to have considered and addressed.

First, I'd like clarification on what problem the redesign is intended to solve. If the concern is poor performance or inappropriate practices by certain providers, what is lacking in the current monitoring, auditing, credentialing, and managed care oversight process that these are not able to be addressed in the current model? How will this new model address ensure that these inappropriate practices do not continue? Is there an alternative solution that has not been fully explored to grant DMAS and the MCO's the authority to remove poor performing entities?

Services Facilitation should not be characterized as merely administrative. In practice, facilitators help individuals and families resolve payroll and application issues, navigate fiscal agent systems, address authorization questions, explain and understand employer responsibilities, and connect with local resources.  

I am particularly concerned about the effect on rural Virginia.  In Western and Southwest Virginia, where the proposed transition begins, provider networks are already limited and travel distances can be substantial.  A statewide network on paper is not the same as a dependable local service who knows their community.  Prior to any roll-out it should be demonstrated that qualified Support Brokers will be available in every region, including rural and underserved communities, before ending the existing model.  The standard must be more than uniterrupted authorizations; it needs to include responsive and knowledgeable assistance when families need it.

There should be a clear path for established private and nonprofit organizations to participate.   I have concerns that Support Brokers could be independent contractors.  Independent contractors raises concerns and questions about the loss of organizational infrastructure, supervision, staff backup, training, and continuity that consumers now receive.  During the 2016 DD Waiver redesign, qualified private providers had a process to express interest, respond to requests for proposals, and establish contracts well before transition deadlines.  Will DMAS and the fiscal agents offer a comparable opportunity for qualified entities to contract? Virginia should not lose proven community-based capacity.

Finally, the implementation schedule must be reconsidered.  With public comment closing on October 17, 2026 the proposal still faces federal review, and contracting terms-if offered-compensation, training, staffing, and consumer notification cannot be responsibly finalized in the absence of approved requirements.  Organizations must make decisions about retaining staff and accepting new consumers.  I respectfully request that implementation begin no sooner than six months after CMS approval and the establishment of workable contracting and reimbursement arrangements.  I also request that DMAS require documented regional readiness before any Services Facilitation ends.

The goals should be a service system that is accountable and easier for individuals to utilize.