Dear DMAS Leadership,

I am writing to express my strong opposition to the proposal to eliminate standalone Service Facilitation (SF) in Virginia. On behalf of the individuals and families who rely on waiver services, I urge the Department of Medical Assistance Services (DMAS) and the Centers for Medicare & Medicaid Services (CMS) to preserve independent Service Facilitation in its current form.

Removing service facilitation would significantly disrupt the lives of individuals with disabilities and their families. Service facilitators act as essential navigators, advocates, and administrative guides. Eliminating this role creates a severe gap that families are not equipped to fill—even if these services are transitioned to a statewide agency or centralized entity.

The primary concerns and negative impacts of this proposed change include

      - Loss of Medicaid Compliance Experts: Facilitators navigate strict, changing waiver regulations. Without them, families risk administrative errors that could lead to a loss of coverage.

  - Loss of Essential Advocacy and Navigation:

      - System Fragmentation: Removing a single point of contact forces families to navigate multiple state agencies, managed care organizations (MCOs), and providers alone.

      - Delayed Service Delivery: Proactive advocacy for care plan adjustments will be lost, leaving individuals without timely support.

      - Unprotected Individuals: Vulnerable individuals without strong natural support systems will lack an advocate for their health, safety, and rights.

  - Decline in Quality of Care and Safety:

      - Loss of Oversight: Eliminating regular, required visits removes vital monitoring, increasing risks to health and safety.

  - Increased Long-Term Costs to the State:

      - Involuntary Institutionalization: Paperwork errors and caregiver burnout will drive more individuals into costly emergency rooms, hospitals, and long-term care facilities.

      - Crisis-Driven Management: Moving away from proactive facilitation shifts the system to an expensive, reactive crisis-response model.

Waiver members and families do not want corporate support brokers assigned by a centralized fiscal-employer agent or managed care organization. We need to maintain independent Service Facilitators because:

1. True Advocacy Must Be Independent: A support broker employed by a corporate fiscal agent or insurance provider cannot objectively advocate for a family when issues arise with that same system.

2. Relationships Matter: Localized, dedicated facilitators know our families, understand our medical needs, and manage immediate crises far better than a rigid corporate broker.

3. Preserving Participant Choice: Forcing an end to standalone Service Facilitation strips families of their right to choose the provider they trust.

Administrative convenience should not take priority over the safety, stability, and voices of the 26,000 Virginia families who rely on consumer-directed services. Please hear the voices of the disability community and preserve standalone Service Facilitation.

Moms in Motion has been a huge support system for my family and many others in the rural area we live in. Our individuals have already been given a challenging life please help us keep them a priority when making these decisions. 

Sincerely,

Jen