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10/8/26  4:05 pm
Commenter: Kathleen Goolsby

Opposition to Replacing Service Facilitation With a Brokerage Model
 

I am writing as the parent of an almost 16-year-old child with autism and intellectual disability to strongly oppose replacing service facilitation with a brokerage model.

I am not writing about an abstract policy change. I am writing about my child and about the people and relationships that help our family navigate a system that can already be incredibly difficult to understand and manage.

Raising a child with autism and intellectual disability requires constant advocacy. We must understand complicated programs, coordinate services, make difficult decisions, anticipate future needs, and continually advocate for supports that will allow our child to be safe, healthy, included, and as independent as possible. Having a trusted service facilitator who understands our family and our child's individual needs has made an enormous difference.

It was not easy to find someone we trusted.

When you have a child with significant disabilities, you cannot simply assume that the next person assigned to your family will understand your child. Every individual is different. My child's needs, communication, behaviors, abilities, challenges, preferences, and goals are unique. It takes time to learn those things. It takes time to build trust. And it takes even longer to develop the kind of relationship where a family feels comfortable relying on someone for guidance and advocacy.

Our service facilitator has become an important part of that support system.

They know our history. They understand our circumstances. They know what our child needs and why. They understand the challenges we have faced and can help us navigate problems without requiring us to start from the beginning every time something changes. That continuity is incredibly valuable.

Replacing that relationship with an assigned broker would not feel like a simple administrative change to our family. It would mean potentially losing a person who has invested time in understanding my child and replacing that established relationship with someone who may have little or no knowledge of our family's history or my child's individual needs.

For a child with autism and intellectual disability, that matters.

Consistency matters. Familiarity matters. Trust matters. Understanding matters.

As my child approaches 16 and gets closer to adulthood, these things matter even more. We are entering a critical period in which we must begin planning for adulthood, increased independence, employment, community participation, and the many challenges that come with transitioning from childhood services into adult systems. This is not the time to disrupt established relationships and make families start over with new people who may not know their child.

I am also deeply concerned about what this change would mean for the principle of choice and self-determination. Families and individuals with disabilities should have meaningful control over the people who help them access and manage their support. Choice should mean more than choosing from a system that has already decided who will assist us. It should mean having the ability to maintain relationships with providers who have earned our trust and demonstrated that they understand our needs.

A brokerage model may appear efficient on paper, but efficiency should never come at the expense of individualized support, continuity, or the human relationships that make these systems work for real people.

For my family, our service facilitator is not just a name on a service plan. This is a trusted person who has become familiar with my child and our family's needs. Losing that relationship would create additional stress and uncertainty for our family and could have real consequences for my child.

I ask CMS to consider the families behind this policy change. Please consider the countless hours parents spend advocating for their children, the difficulty of finding professionals we can trust, and the enormous importance of having someone who truly knows our child. Please consider what it means to ask families to give up relationships that may have taken years to establish.

People with disabilities are not interchangeable cases, and the professionals who support them should not be treated as interchangeable either.

My child deserves a support system built around their individual needs, their strengths, their challenges, and the people who know them best. Our family deserves the ability to choose and maintain the trusted relationships that help make that support system possible.

I strongly urge CMS to reject this change and preserve the ability of individuals and families to choose their service facilitators. Please protect continuity, meaningful choice, self-determination, and person-centered support.

For families like mine, this is not simply about changing a service model. It is about changing the relationships we depend on to help our children have the safest, most independent, and most meaningful lives possible.

Please listen to the families and individuals who will be directly affected. We are asking you to protect the relationships, choices, and supports that allow our children to thrive.

CommentID: 242262