Strong Opposition to General Notice 3470 – Elimination of Independent Services Facilitation and Tran
Dear Representatives of the Virginia Department of Medical Assistance Services (DMAS),
I am writing to express my extreme disapproval and absolute opposition to the proposed waiver amendments seeking to eliminate independent Services Facilitation and transition to a centralized "Support Brokerage" model controlled by a Fiscal-Employer Agent.
I am speaking directly from the trenches as a parent and Employer of Record (EOR) for my son, who is a living, breathing, beautiful young man battling multiple complex health issues and profound, nonverbal autism accompanied by severe, violent behavioral episodes. Our daily life is defined by acute medical necessity, constant safety monitoring, and high-stress crisis management.
Caring for a child with these profound needs is a 24/7 reality—it is not a corporate transaction. A Medicaid waiver is a medical necessity, not a commodity. Managing my son’s life should not be treated like buying an automobile, purchasing a financial product, or dealing with a corporate broker who looks at my son as a line item on a spreadsheet to cut costs. Corporate brokers do not understand the terrifying reality of a mental health crisis, the extreme family impact, or the physical and psychological toll this takes on an entire household.
When a person without a disability needs medical care, they get to go straight to a doctor. They do not have to go through a corporate healthcare brokerage just to figure out what their current needs are—they go directly to the provider and they actually receive healthcare. People with disabilities should have that exact same right. We should not be forced through layers of financial brokers just to access basic, necessary care.
My son has recently aged out of the school system, and we are currently fighting to secure the essential adult services he needs to survive in the community. Navigating this terrifying transition would be impossible without our local, independent Services Facilitation agency, The Disability Resource Center in Fredericksburg, and our dedicated facilitator, Latoya. Latoya has worked tirelessly for our family, going far beyond the scope of a standard 9-to-5 job. She has texted me late at night and answered my calls on weekends because she knows that a crisis does not wait for business hours.
A centralized, state-contracted healthcare broker sitting in a call center will not be there for us.
When my son is having a violent episode, a corporate broker will not answer a late-night text to help me figure out emergency safety interventions or preserve our care plan.
When an attendant abruptly quits due to the dangerous nature of my son's behaviors, a broker will not care about the immediate safety crisis in our home—they will treat it as a routine administrative delay.
My son is a human being with a right to a safe life; he is not a cost to be cut, and he is not collateral damage. Stripping away our independent advocates to save money tells vulnerable families that we are entirely on our own when a crisis erupts.
I strongly urge DMAS and Virginia lawmakers to reject General Notice 3470. Please preserve standalone, independent Services Facilitation, protect local agencies like The Disability Resource Center, and protect the families who rely on real, local, human advocacy like Latoya’s to survive.
