I am commenting to express strident opposition to any regulatory or structural changes that would eliminate or diminish the current Services Facilitation model. Services Facilitation is the critical mechanism maintaining my brother’s health, safety, and successful placement in the community. As a severely disabled 9/11-survivor, he lives with profound, permanent clinical needs and has already endured a lifetime of trauma and immense loss.

Our Services Facilitator is not merely an administrative contact; they are the sole anchor of stability in his continuum of care. The consumer-directed model provides our family with the vital autonomy required to select, train, and manage trusted attendants who understand his complex history. This specific framework ensures we have a dedicated advocate to call in acute moments of crisis, effectively preventing medical regression and unnecessary institutionalization.

We have previously attempted agency-directed care, and it was a catastrophic failure. The model resulted in high staff turnover, transient and subpar providers, and systemic gaps in care that actively jeopardized his health and safety.
For a Medicaid member who has survived what my brother has, consistency is not a preference—it is a clinical necessity. Eliminating or fundamentally altering the Services Facilitation infrastructure will strip away the reliable, effective care he depends on to survive. 

It is particularly concerning that DMAS suggests a central broker to manage hundreds of clients starting as soon as this Spring yet there is no transparency regarding the details of what this will look like in practice.

We implore CMS to reject any proposed transitions away from Services Facilitation, protect member autonomy, and preserve the stability of consumer-directed waivers.