To the Virginia Department of Medical Assistance Services and CMS:

I am a Virginia Beach parent and Employer of Record for my daughter's consumer-directed care under the CCC Plus Medicaid waiver. I am submitting this comment to express my serious concerns and opposition to the proposed elimination of independent Services Facilitation.

As a parent responsible for a child with disabilities, I can tell you firsthand that navigating Virginia's Medicaid waiver system is already complicated enough. Families like mine depend on knowledgeable service facilitators for guidance, accountability, and assistance in understanding a system that directly affects our children's health, safety, and daily lives.

What concerns me most is the proposed removal of our ability to choose an independent service facilitator. Consumer-directed care is supposed to empower individuals and families to make decisions about their own care. How does eliminating our choice of service facilitation provider support that principle?

I am also concerned about placing Support Brokers under the same Fiscal/Employer Agents responsible for other administrative aspects of our care. Who will independently advocate for families when problems arise with those agencies? What protections will prevent conflicts of interest? And who will be accountable if this transition disrupts essential services?

The state should be able to answer these questions before moving forward, not after thousands of vulnerable individuals and families have been transferred into an unfamiliar system.

I believe families deserve clear answers to several basic questions:

-Why must independent service facilitators be eliminated rather than allowing families to choose between the existing model and Support Brokers?

- Will families be permitted to choose or change their assigned Support Broker?

- What independent oversight and complaint procedures will protect recipients?

- How will Virginia guarantee continuity of care, authorized services, and reliable assistance throughout the transition?

- What evidence demonstrates that this new model will improve outcomes for the individuals it is supposed to serve?

I understand the importance of responsible spending and program oversight. However, administrative efficiency should never come at the expense of consumer choice, independent advocacy, or the stability of care for people with disabilities.

I urge DMAS and CMS to reconsider eliminating independent Services Facilitation. At a minimum, the transition should be delayed until families have meaningful opportunities to participate, clear written answers, and enforceable protections against disruptions in care.

Families should not have to sacrifice their right to choose trusted support simply because the state wants to change how services are administered.

Please listen to the parents, caregivers, and individuals whose daily lives depend on these programs. We are not just case numbers in a system. We are families trying to provide the safest and most stable lives possible for our loved ones.

Thank you for considering my public comment.

A concerned Virginia Beach parent and Employer of Record