I am writing to express my strong opposition to the proposed changes affecting Virginia’s Medicaid Home and Community-Based Services waivers, particularly those involving independent service facilitation, the proposed support broker model, the expansion of the 56-hour weekly soft cap, and changes to oversight and procedural protections.

I am a Virginia resident, a mother, and a family caregiver for an individual receiving services through the Commonwealth Coordinated Care Plus (CCC+) waiver. I have firsthand experience navigating the consumer-directed care program through Public Partnerships (PPL), including managing attendant care, respite services, electronic timekeeping, and the administrative responsibilities associated with providing care for a loved one with disabilities.

I recognize the importance of accountability, oversight, and responsible stewardship of public funds. However, I firmly believe that administrative efficiency should never come at the expense of the individuals with disabilities and families these programs were designed to support.

Preserving Independent Service Facilitation and Consumer Choice

I strongly oppose eliminating independent service facilitators and replacing them with a statewide support broker model.

My personal experience demonstrates the importance of preserving independent service facilitation and consumer choice. When my longtime service facilitator left her previous agency to establish her own business, I chose to continue working with her because of the trust, familiarity, and professional relationship we had developed.

My facilitator is accessible and generally responds to questions or concerns within 24 hours. Although I rarely need assistance, knowing that she or a member of her staff is available when needed provides invaluable peace of mind.

As a parent and caregiver, I believe families should retain the freedom to choose qualified, independent professionals who understand their circumstances and have earned their trust. I am concerned that the proposed support broker model could jeopardize that continuity, independence, and accessibility.

Concerns Regarding Expansion of the 56-Hour Weekly Soft Cap

As the caregiver of an individual receiving services through the CCC+ waiver, I am familiar with the existing 56-hour weekly soft cap on personal care. Although the proposed expansion would not introduce a new cap for CCC+ participants, I am concerned about extending similar restrictions to individuals receiving services through other waivers.

Care requirements should be determined by each individual’s assessed needs. While exceptions may be available, families should not face unnecessary administrative obstacles when seeking the level of care their loved ones require.

Concerns Regarding Electronic Visit Verification Requirements

I also strongly oppose Virginia’s decision to eliminate the Electronic Visit Verification exemption for live-in caregivers, effective October 1, 2026.

As a live-in family caregiver, I am already experiencing the effects of this new requirement. I now must clock in and out using an approved electronic system for my attendant and respite shifts.

I understand the importance of accurate timekeeping and accountability. However, caring for a family member within the same household is fundamentally different from reporting to a conventional workplace. Caregiving responsibilities do not always begin and end neatly according to an electronic clock.

I am concerned about the additional administrative responsibilities imposed on family caregivers who are already managing complex care needs. I urge DMAS to reconsider the removal of the live-in caregiver exemption and recognize the unique circumstances of families providing care within their own homes.

I recognize that this EVV change is separate from the waiver amendments currently under consideration, but it illustrates the cumulative administrative responsibilities placed upon family caregivers.

Maintaining Oversight and Procedural Protections

I oppose any reduction in independent oversight or procedural protections affecting waiver eligibility and services.

Individuals with disabilities and their families deserve transparency, accountability, and meaningful opportunities to challenge decisions that could affect their health, safety, independence, and continuity of care.

The Human Impact of These Decisions

Family caregivers are not simply employees completing scheduled tasks. We are parents, advocates, household managers, and often the individuals providing the greatest continuity and stability in the lives of our loved ones.

Every additional administrative responsibility requires time and attention that could otherwise be devoted to caregiving.

I respectfully urge DMAS to reconsider these proposed changes, preserve independent service facilitation, protect consumer choice, maintain meaningful oversight, and engage directly with the families who depend upon these services.

The success of any Medicaid waiver program should be measured not only by administrative efficiency but also by how effectively it supports the dignity, independence, and well-being of the individuals it serves.

People with disabilities deserve dignity, stability, and individualized care. Their families deserve support, not additional barriers.

Thank you for considering my comments.