Subject: Strongly Oppose the Elimination of Services Facilitation and other changes
Consumer-Directed Services
I am a parent and Employer of Record in Northern Virginia, writing to strongly oppose the proposed elimination of independent Services Facilitation and the transition to a centralized Support Broker model.
My son is severely disabled and medically requires 24-hour total care to remain safe in our home. Despite his profound medical needs, the system recently cut his hours down to just 52.5 hours per week. I am currently working with two of his medical specialists who are writing formal letters certifying that his condition requires round-the-clock care.
This proposed transition does not benefit consumers; it strips away humanity and builds a system designed to cut costs at the expense of vulnerable individuals.
My specific objections to these changes are:
Severe Conflict of Interest: Independent Services Facilitators are critical allies for families. They understand our children's medical histories and advocate for us to secure necessary care. Absorbing facilitators into the Fiscal Employer Agents (PPL/CDCN) creates a massive conflict of interest. A Support Broker paid by the entities managing the state's Medicaid funds will face inherent pressure to restrict or deny authorizations rather than advocate for the consumer's maximum needs.
Compounding an Already Broken System: DMAS is already cutting hours for individuals who desperately need them, as evidenced by my son's recent reduction. Forcing families to navigate a monolithic, centralized broker system without independent guidance will make appealing unfair hour reductions nearly impossible for exhausted caregiving families.
The Invisible Burden of "Soft Caps": While DMAS claims hours above 56 are accessible via exceptions, the administrative burden of constantly re-proving profound disability creates a barrier that naturally results in vulnerable individuals losing the care they require to survive safely in the community.
DMAS must preserve independent, third-party Services Facilitation to ensure families have conflict-free advocacy. I urge DMAS and CMS to reject these amendments, prioritize the humanity of the individuals these waivers are meant to serve, and stop implementing measures that restrict vital care hours.
