We strongly oppose the proposed elimination of standalone Services Facilitation within Virginia's Medicaid waiver programs.

Families of children and adults with disabilities depend on a reliable support system to help them navigate the complex requirements of consumer-directed services. Services facilitation plays an important role in helping families understand program requirements, maintain documentation, develop plans of care, and address questions and problems as they arise.

This proposal is not simply an administrative adjustment. It is the elimination of an established support structure and the transfer of its responsibilities into a different model, with potentially significant consequences for the individuals and families who depend on these services.

Services facilitators develop knowledge of the families they serve and become familiar with their individual circumstances and support needs. That continuity, experience, and understanding cannot automatically be replicated by changing the structure through which services are delivered.

Consumer-directed care already places substantial responsibility on families and caregivers. They must navigate program requirements, maintain documentation, coordinate care, and ensure that the needs of individuals with disabilities are met. Removing an established layer of support risks creating additional uncertainty and administrative burdens for families who are already managing significant responsibilities.

An established service should not be eliminated before a reliable replacement has been demonstrated to protect the people who depend on it. Transferring responsibilities to a new model does not, by itself, guarantee equivalent access, continuity, accountability, or individualized assistance.

There are serious concerns about how this transition would function in practice. Families need dependable access to knowledgeable professionals when questions arise, paperwork requires correction, authorizations become complicated, or urgent assistance is needed. They cannot be expected to absorb the consequences of inadequate staffing, delays, confusion, or gaps in oversight while a new system works through its implementation.

For children and adults with disabilities, disruptions in the support surrounding their services can have consequences extending far beyond administrative inconvenience. Their families need stability, clear guidance, and confidence that the systems responsible for supporting them will remain accessible and responsive.

Efficiency and accountability are important goals, but consolidation alone does not guarantee either outcome. If improvements to the existing model are necessary, those concerns should be addressed directly. Eliminating an entire service category is not proof that underlying problems will be resolved, and restructuring can introduce new challenges if its effects on families are not adequately considered.

Experienced service facilitators represent an existing source of professional knowledge and established relationships with families. Any proposed restructuring should carefully consider the value of that experience and the potential consequences of losing continuity for the individuals receiving services.

I urge DMAS to stop the proposed elimination of standalone Services Facilitation and reconsider this approach before dismantling the existing support structure. Any future proposal should be supported by a clear and transparent implementation plan, demonstrated operational readiness, adequate staffing, meaningful accountability, and enforceable protections for the families and individuals who depend on these services.

Families should not have to discover the weaknesses of a replacement system after the existing system has already been dismantled. Nor should children and adults with disabilities bear the consequences of administrative decisions made without sufficient safeguards for continuity, quality, and access to support.

DMAS must demonstrate how any replacement model will preserve the essential functions families currently rely on, maintain access to knowledgeable professionals, protect continuity of service, and prevent administrative failures from jeopardizing authorized care.

Children and adults with disabilities, along with the families who support them, deserve a dependable system that prioritizes their needs and protects the stability of essential services. These individuals should not become an afterthought in an administrative restructuring.

I respectfully urge DMAS to reconsider this proposal and refrain from eliminating standalone Services Facilitation until a genuinely workable replacement has been demonstrated to protect the individuals and families who rely on it.