I am submitting this comment as a Virginia developmental-disability service provider who has worked directly with individuals receiving waiver services and who is developing an additional residential service model in Virginia.

I support accountability, appropriate oversight, responsible Medicaid spending, and modernization of the waiver system. However, I am deeply concerned when administrative changes begin to replace individualized, person-centered decision-making with standardized limits or structures that may be easier to administer but do not reflect how people with developmental disabilities actually live.

My primary concern with the proposed 56-hour weekly “soft cap” on personal assistance is that waiver services are supposed to be based upon assessed individual need. A person does not stop needing assistance because an arbitrary weekly number has been reached. Individuals with developmental disabilities may require assistance with hygiene, meals, communication, health and safety, mobility, community access, emotional regulation, household responsibilities, and other activities at different times and with very different levels of intensity.

If 56 hours becomes the presumed norm, even with an exception process, I am concerned that a “soft cap” will eventually function as a practical hard cap. Providers, families, and individuals should not have to repeatedly prove that previously established and documented needs are extraordinary simply because those needs exceed an administratively convenient number.

I urge DMAS to preserve individualized assessment as the controlling standard and to make clear that no person will lose medically or functionally necessary supports solely because their needs exceed 56 hours.

I am also concerned about eliminating independent Services Facilitation in favor of a more centralized Support Broker model if doing so reduces consumer choice, continuity, or access to someone who actually knows the individual and family.

One of the greatest weaknesses I see in the current DD system is fragmentation. Residential providers, community services, support coordinators, clinicians, families, employers, and other supports often operate as separate islands. The person receiving services is then expected to somehow exist in the middle of that fragmented system.

The answer should be greater coordination and accountability—not additional separation or centralization that moves decision-making farther away from the person.

Virginia’s waiver services should operate as a bridge. Residential support should connect with community participation. ADL and IADL development should connect with real-life application. Employment, recreation, communication, health, behavioral supports, family involvement, and community engagement should reinforce one another around one individualized plan.

True person-centered planning is more difficult than simply supervising people. It requires time, staffing, communication, creativity, and coordination. But that is precisely why the waiver exists.

I therefore urge DMAS to:

• Preserve individualized assessed need rather than allowing a 56-hour benchmark to become a de facto limitation on personal assistance.

• Establish a transparent, timely, and meaningful exception process for any utilization benchmark, with decisions based upon documented individual need rather than cost alone.

• Preserve meaningful consumer choice regarding Services Facilitation and Support Brokerage and avoid creating a single centralized structure that reduces continuity or local relationships.

• Require continuity protections before transitioning any person from an existing service-facilitation arrangement to a new model.

• Evaluate these changes based not only on administrative efficiency or short-term Medicaid expenditures, but also on their effects on independence, caregiver stability, provider capacity, community participation, and risk of institutionalization.

• Continue including individuals with disabilities, families, direct support professionals, residential providers, service facilitators, and other people working directly in the system in the development and evaluation of these policies.

Virginia has an opportunity to build a genuinely person-centered developmental-disability system. That cannot be accomplished by simply moving people into community settings while continuing to design services around administrative convenience.

Community-based services should not merely surround an individual. They should connect that individual to a meaningful life.

Thank you for considering my comments.

Bradley David Calhoun
Owner
Ember Initiatives Community Services and Wellness Solutions, LLC
Henrico County, Virginia