As the parent of an adult child on the FIS waiver program using Consumer Directed services, I strongly support the Arc of Northern Virginia's comments. I strongly oppose the proposed 56-hour cap on DD waiver CDPA care and replacement of service facilitators with the brokerage model.  It is unclear exactly what this change means, who the brokers would be, how this change would be an advantage over the current process and the downside of limited access to brokers or the inability to change to another broker if one is not working well, for families who need the help to allow their loved ones to access appropriate services and keep them living safely in their homes could be devastating.