Public Comment Regarding the Elimination of Service Facilitation as a Standalone Service in Virginia’s Medicaid Waiver Programs

I am submitting this comment regarding the decision to transition from the existing Service Facilitation model to a statewide Support Broker model.

The August 27, 2025, DMAS bulletin, Consumer-Directed (CD) Services Facilitation (SF) Requirements and Reminders, identified several areas of concern regarding compliance among Medicaid-enrolled Service Facilitation providers. These included missed visits, inadequate communication with members and employers of record, improper documentation of face-to-face visits, untimely authorization submission, electronic visit verification concerns, and other failures to meet provider requirements.

Additionally, at the Service Facilitation meeting held on October 7, 2026, my understanding of the discussion was that concerns regarding Service Facilitators not appropriately fulfilling their responsibilities were a factor in the transition to the new Support Broker model. If these concerns contributed to the decision to eliminate Service Facilitation as a standalone service, I respectfully request greater transparency regarding how those concerns were evaluated and how they influenced the decision to replace the existing model statewide.

I recognize the importance of protecting Medicaid members, maintaining program integrity, and holding providers accountable for meeting established requirements. However, I believe it is equally important to distinguish between providers who fail to meet their responsibilities and those who consistently comply with requirements, maintain appropriate documentation, complete required visits, communicate effectively, and demonstrate a commitment to the individuals they serve.

The actions of some providers should not automatically determine the outcome for all providers. In any profession or service system, individual providers may differ in their performance, compliance, and commitment to quality. When deficiencies are identified, those deficiencies should be addressed appropriately. However, a system-wide decision should consider whether the problems are widespread, whether they are attributable to specific providers or practices, and whether less disruptive alternatives could adequately address them.

I respectfully request that DMAS address the following questions:

Basis for the decision: Did the compliance concerns identified in the August 27, 2025, bulletin, or the concerns discussed at the October 7, 2026, meeting, materially influence the decision to eliminate Service Facilitation as a standalone service? If so, what findings, data, or evaluations supported that decision?

Consideration of alternatives: What consideration was given to addressing noncompliance through targeted corrective action plans, increased monitoring, provider-specific sanctions, caseload restrictions, payment recoupment, or disenrollment of providers that repeatedly failed to meet requirements, rather than eliminating the existing model for all providers?

Recognition of compliant providers: How did DMAS evaluate the impact of this decision on providers with established records of compliance, appropriate documentation, completion of required visits, timely communication, and effective coordination with members, employers of record, support coordinators, Community Services Boards, and managed care organizations?

Fairness and accountability: Were differences in provider performance considered when evaluating the transition? If certain providers were not meeting requirements, what evidence supported applying a statewide change to providers regardless of their individual compliance histories?

Continuity and quality of services: What safeguards will ensure that the transition to a Support Broker model maintains service continuity, access to knowledgeable support, timely communication, and appropriate assistance for individuals who rely on consumer-directed services?

Impact on small providers: What consideration was given to the financial and operational consequences for small providers whose businesses are dedicated primarily or entirely to Service Facilitation, including the loss of established operations, professional relationships, and years of experience supporting waiver participants?

Transparency and supporting documentation: Will DMAS make available the analysis, performance data, stakeholder feedback, and other documentation used to evaluate the existing model and support the decision to replace it?

Service Facilitation providers have developed experience navigating Medicaid waiver requirements and coordinating with members, families, employers of record, support coordinators, Community Services Boards, and managed care organizations. These professional relationships and accumulated knowledge can be valuable to individuals who depend on consumer-directed services. The experience of providers who have consistently fulfilled their responsibilities should be considered when evaluating how best to improve the service system.

I am concerned that a broad policy change may negatively affect compliant providers and the individuals they serve, even when those providers were not responsible for the problems that prompted regulatory concern. If deficiencies were identified among particular providers, I respectfully ask DMAS to explain why replacing the entire model was determined to be necessary and how less disruptive alternatives were evaluated before making this decision.

I also ask DMAS to clarify how the new Support Broker model will address the specific concerns identified in the 2025 bulletin and discussed during the October 7, 2026, meeting. A change in service structure alone does not explain how the underlying compliance issues will be prevented, monitored, or addressed moving forward.

Accountability and fairness should go hand in hand. Providers who fail to meet established requirements should be held accountable, but providers who fulfill their responsibilities should have their performance and contributions considered independently. Addressing the actions of some should not mean overlooking the value, experience, and demonstrated commitment of others.

My intention in raising these concerns is not to dismiss legitimate compliance issues or to suggest that the existing system should be exempt from improvement. Rather, I respectfully ask that significant policy decisions affecting an entire service system be supported by transparent evidence, careful evaluation, and consideration of the consequences for both Medicaid members and providers who have worked to meet program expectations.

I urge DMAS to provide a clear explanation of the evidence and reasoning underlying this transition, clarify how provider performance and alternative approaches were considered, and demonstrate how the new model will protect the quality, continuity, and accessibility of consumer-directed services for Virginia Medicaid members.