We understand and appreciate DMAS's efforts to improve efficiency, consistency, and accountability within Virginia's consumer-directed services system. However, we respectfully ask DMAS to carefully consider what may be lost when community-based Service Facilitators are replaced by, or incorporated into, a centralized statewide model.

During a recent DMAS town hall, DMAS reported receiving complaints regarding Service Facilitation. Claims data indicated that many members were not receiving all required Service Facilitator (SF) visits. Addressing these concerns is important; however, we encourage DMAS to evaluate not only whether required visits are completed, but also the broader role Service Facilitators play in supporting consumers and families.

From our experience working directly with individuals receiving consumer-directed services, many consumers and families are already confused by the number of individuals and organizations involved in their care. It is common for multiple professionals to visit the home to conduct assessments, complete paperwork, monitor services, and review eligibility requirements.

Consumers frequently ask who these individuals are, why additional assessments are necessary, and whom they should contact when they need assistance. We have also encountered consumers who do not know or have never met their assigned Care Coordinator, or who experience difficulty obtaining assistance when concerns arise.

Because Service Facilitators often live and work in the same communities as the individuals they serve, they develop strong working relationships with consumers, Employers of Record (EORs), attendants, families, and caregivers. Through regular face-to-face contact, they gain an understanding of each individual's circumstances, needs, and local resources that cannot easily be replicated through a centralized system.

This local knowledge becomes especially important because individuals receiving Medicaid Waiver services often face challenges that extend beyond their authorized personal care or respite services. Families frequently need assistance locating information and resources related to:

While Service Facilitators may not be responsible for providing all of these services directly, they are often the first and most accessible point of contact for individuals and families seeking guidance. Their community connections and knowledge frequently help consumers obtain the support they need more quickly and effectively.

Consumer direction should remain centered on the individual. While a statewide model may improve administrative consistency, efficiency should not come at the expense of personal relationships, local knowledge, accessibility, continuity, and meaningful consumer choice. Individuals and families who already struggle to navigate complex systems. When issues arise involving authorizations, attendant enrollment, timesheets, transportation, housing, or other service-related concerns, consumers may not know which agency or organization is responsible. In many cases, their Service Facilitator serves as a trusted and accessible resource who helps them identify the appropriate next steps and connect with the right supports.

Many Service Facilitators have worked with the same individuals and families for years and understand their communication styles, family circumstances, support systems, attendants, and community resources. Consumers and families know whom to call when circumstances change, when they have questions, or when they need assistance navigating a complex Medicaid system.

Transitioning these responsibilities to a new statewide structure may disrupt established relationships and require individuals and families to start over with someone who may not know them, their history, or the resources available in their community.

Questions to DMAS:

As DMAS evaluates potential changes, we respectfully urge consideration of the value that Service Facilitators bring through established relationships, local knowledge, continuity of support, problem-solving, education, and advocacy. These contributions align with the goals of CCC+ (Commonwealth Coordinated Care) by ensuring members receive consistent, person-centered services through effective collaboration with Managed Care Organizations (MCOs) and locally based care coordinators, resulting in more coordinated and responsive care. Community-based support is most effective when those providing that support understand the communities in which individuals live, work, and receive services.

This introduced proposal raises many unanswered questions and areas of uncertainty, especially considering the limited timeframe for implementation such as Important details regarding Support Broker qualifications, caseload expectations, training requirements, oversight, and the impact on the cost-effectiveness of consumer-directed services have not yet been clearly defined. Moving forward without addressing these uncertainties may create confusion for consumers, families, and providers and could jeopardize the continuity and quality of support that individuals currently receive. We respectfully request that DMAS provide greater clarity and stakeholder input before implementing these significant changes.

Thank you for considering this public comment and for providing stakeholders the opportunity to participate in this important decision.