Commenter:
Michala Conroy, Consumer Direct Care Network
HCBS Waiver Amendments 1/01/27 NO to support cap and NO to brokers
To Whom It May Concern:
I work for families who are Caregivers and am also a Caregiver of young adults with special needs who rely on personal care services for support in many basic activities of daily living. The care needs of these individuals include a vast variety of assisted supports, tasks and oversight including but not limited to: bathing, dressing and undressing, toileting and incontinence care, transferring, eating, turning and changing position, personal grooming, supervision and safety provisions, meal and snack preparation, cleaning up after meals, shopping, transportation and support to medical appointments, medication support and support for social and work activities.
For many with High Support Autism this also includes 1-1 care directed at constant elopement and safety issues and monitoring and support during epileptic seizures.
These are 24/7 issues that cannot just be “reduced” simply due to a budgetary goal. I cannot and will not leave a client just because their budgetary changes but this causes me to not make the money I need to make to survive. For many, these are not extra services or conveniences but rather necessary supports that allow these individuals to remain safe and participate in daily life. These are not individuals with ordinary or temporary care needs. Their need for assistance has already been well established through multiple layers of eligibility and assessments for YEARS.
The Virginia “Developmental Disability” (DD) Waiver exists in large part to enable people with significant disabilities to remain safely in their home and communities RATHER than entering isolating, limiting and expensive institutions.
I strongly OPPOSE the proposed 56-hour weekly cap on personal care/assistance under the 1915(c) HCBS waivers. A blanket cap does not account for the fact that waiver participants have different disabilities, health needs, living situations, schedules, and amounts of available unpaid support. What one person needs in eight hours may be very different from what another person needs. And life is NOT an “Only 8 hours a Day of Support Needs” Reality for many current Waiver recipients.
We ask that VA DMAS, State Delegates and Governor Spanberger seriously reconsider this proposal and stand up for the true needs of many of its Disabled Citizens. Families, caregivers and individuals should not have to navigate an increasingly complex administrative process simply to preserve services that have already been determined to be medically and functionally necessary.
NO to BROKERS:
While the state is implementing this change from "Service Facilitation" to "Support Brokers" to reduce administrative costs and streamline paperwork - many Individuals, Families, and Advocacy groups (such as The Arc of Virginia, The Virginia Autism Project, etc) argue that Services Facilitation is better for waiver recipients for several key reasons:
*Trusted, Long-Term Personal Relationships
Under the Services Facilitation model, families choose their own local coordinator. Many families work with specialized agencies like “Moms In Motion” or “Toddlers to Grandparents” or independent facilitators for years, building deep trust. Support Brokers, conversely, will be managed and assigned by a single statewide Fiscal-Employer Agent (F/EA) contractor. Families worry this will turn a highly personal role into an impersonal corporate helpline.
*Loss of Consumer Choice
Currently, if a family is unhappy with their Service Facilitator, they can freely fire them and hire another agency or independent provider. Under the Support Brokerage model, options are heavily restricted because the brokers work directly under the contract of the state's chosen fiscal agent.
*Understanding of Local and Regional Barriers
Local Service Facilitators live and work in the same communities as their clients. This gives them firsthand knowledge of regional barriers, local staffing shortages, and community-specific resources. Advocates fear centralized Support Brokers will lack geographic familiarity, heavily disadvantaging rural regions like Southwest Virginia.
*Specialized Care and Clinical Expertise
Many existing Services Facilitators are Registered Nurses (RNs) or highly trained disability advocates who understand complex behavioral and medical needs. Because Support Brokerage is largely being driven by state budget-cutting measures there are severe community concerns that the quality, credentialing, and frequency of high-touch care oversight will drop.
PLEASE listen to the actual consumers and understand why this is so scary and distressing for the families, workers, and individuals themselves and vote NO to a support cap and NO to brokers.
