As both a Services Facilitator and the parent and caregiver of a special needs child, I strongly oppose the proposal to eliminate Services Facilitation and replace it with a Support Broker model housed inside the Fiscal-Employer Agents. I write not only for myself, but for the many family members and friends in my life who care for children and adults receiving waiver services, we share the same concerns.

Service Facilitators do far more than process paperwork. We work closely with families over months and years, building professional, trusting relationships. As a caregiver myself, I know firsthand how much it matters to have one consistent, independent person who knows your loved one, understands your household's circumstances, and can advocate for your family when problems arise; with managed care organizations, with authorizations, and with the very fiscal agents this proposal would hand our responsibilities to. That independence matters. A broker employed by the fiscal agent cannot advocate against that same agent's delays and errors. This is a built-in conflict of interest, and it strips a critical check and balance out of the system our most vulnerable Virginians depend on.

My second concern is practical: fiscal agents are already very slow processing enrollment paperwork, and families already find it difficult to communicate with them. I hear this constantly from the families I serve and from my own circle. Adding assessments, Plans of Care, and quarterly visits to entities already struggling with responsiveness will not improve support, it will make it worse. I do not believe brokers employed by fiscal agents will be as responsive as the facilitators families rely on today, and DMAS has not answered basic operational questions: will a family see the same broker at each visit or a rotating cast of strangers? What will caseloads be? How will a broker build the relationship that makes facilitation work?

Third, the name itself reveals the problem: "support broker" sounds like a financial relationship, not a caregiving one. Families need a person who knows their loved one, not a brokerage function.

Fourth, this change eliminates the jobs of experienced facilitators across Virginia, people with years of specialized knowledge walking out the door just as families are forced into an untested model.

Finally, the recent town hall on this proposal was disorganized, with a large number of questions left unanswered. Moving forward with a change this sweeping while fundamental questions about continuity, responsiveness, caseloads, and conflicts of interest remain unanswered is not responsible policymaking.

 I urge DMAS to preserve Services Facilitation as a standalone, independent service.

Services Facilitator and Parent Caregiver