Opinion: Why state leadership, coordinated systems, and person-centered supports matter regardless of federal agency change.

Over the past several weeks, two significant federal developments have generated discussion across disability, education, healthcare, and policy communities.
The first is a memorandum issued by the U.S. Department of Justice’s Office of Legal Counsel examining the scope of federal authority under the Americans with Disabilities Act (ADA), the Rehabilitation Act, and the Supreme Court’s Olmstead decision regarding institutional and community-based services for individuals with disabilities.
The second is the federal government’s decision to transfer certain disability-related educational oversight responsibilities, including functions associated with the Individuals with Disabilities Education Act (IDEA) and Section 504, from the U.S. Department of Education to other federal agencies, including the Department of Health and Human Services and the Department of Justice.
Both developments have generated strong reactions, and supporters argue these changes may clarify agency authority, improve coordination, and provide states with greater flexibility in designing systems of care. However, critics have expressed concerns regarding disability rights protections, educational supports, community integration, and long-term impacts on individuals with disabilities and their families. What interests me most, however, is a different question:
Regardless of how federal agencies are organized or how federal laws are interpreted, what responsibility do states, particularly Virginia, have to ensure individuals with disabilities and their families receive the supports they need to live meaningful, self-directed lives?

Where Does Virginia Stand?
At the time of this writing, Virginia has not issued a formal public response to the DOJ memorandum, which is at its core an opinion piece. Also, there has been no official statement from the Governor’s Office, the Secretary of Health and Human Resources, the Department of Behavioral Health and Developmental Services (DBHDS), the Department of Medical Assistance Services (DMAS), or other state agencies outlining how the Commonwealth may respond to these federal developments. While Virginia’s position on the legal questions remains unclear, it's recent investments tell an important story. Over the past several years, Virginia has continued to invest in:
- Medicaid Home and Community-Based Services (HCBS)
- Developmental disability waiver programs
- REACH crisis services
- Behavioral health transformation initiatives
- Employment supports
- Community-based services
- School-to-adulthood transition efforts
- Workforce development initiatives
These investments reflect a continued commitment to improving outcomes for individuals with disabilities and their families. Importantly, none of these needs disappear because of a federal memo or agency reorganization.

Families Do Not Experience Services Through Government Agencies
When disability policy discussions occur at the federal level, it is easy to focus on organizational charts, legal authorities, and agency responsibilities. However, families experience something very different. While policymakers are arguing over "the red tape", parents are trying to navigate:
- Early intervention services
- Special education supports
- Healthcare systems
- Behavioral health services
- Medicaid waivers
- Employment programs
- Housing options
- Crisis response systems
Families do not separate these services into federal departments because we experience them as a single journey. A child receiving special education services today may need behavioral health supports tomorrow, vocational services in young adulthood, residential supports later in life, and aging services decades down the road. The systems may be separate on paper, but for families, they are deeply interconnected.
The DOJ memorandum has sparked debate because it challenges long-standing interpretations regarding the federal government’s role in promoting community integration under the ADA and the Rehabilitation Act. Supporters of the memorandum argue that it appropriately limits federal agencies to the authority granted by Congress and allows states greater flexibility in determining how services are delivered. However, critics of the memo argue it may weaken protections against unnecessary segregation and reduce incentives for states to invest in community-based supports. I understand these fears. In a time when we are seeing rights become challenged and even overturned, I can see how a memo caused this much concern. The legal questions matter, and they deserve thoughtful discussion among policymakers, advocates, providers, and legal experts. However, regardless of where those debates ultimately lead, individuals with disabilities will still need access to quality services and supports. The need for services does not change because legal interpretations change.
A Strong Disability System Requires More Than Compliance
One of the risks in any policy debate is focusing exclusively on compliance. We all can agree that compliance is important, but families ultimately measure success through outcomes.
- Can they access services when they need them?
- Can their loved one safely participate in the community?
- Can they find qualified providers?
- Can they access crisis supports before a situation escalates?
- Can young adults successfully transition from school into employment, higher education, or adult services?
- Can individuals achieve the goals they set for themselves?
These are the questions that define the effectiveness of a disability support system. The goal should not simply be compliance with minimum requirements. but to help people thrive. When citizens are thriving and have adequate resources, it is reflected through the economy. Disability services are most effective when they recognize that individuals have different needs at different points in life. Some individuals thrive with independent living supports, competitive employment, and community-based services, while others may require intensive behavioral supports, specialized residential services, medical oversight, or crisis intervention. Many individuals will need different levels of support throughout their lives, and the conversation should not be framed as community services versus institutional services. The conversation should focus on ensuring that individuals have access to the right support, at the right time, in the setting that best meets their needs, preferences, and goals. Person-centeredness is a principle that Virginia holds dear. This is the principle that has propelled all of my advocacy work over the last 10 years. Person-centered planning requires flexibility because no two individuals have identical needs.
Coordination May Be Virginia’s Greatest Opportunity
Recent federal discussions highlight something disability advocates, providers, and families have known for years and that's people do not live within a single system. We all move between education, healthcare, behavioral health, employment, housing, transportation, and community support systems throughout our lives. Yet these systems are often funded, regulated, and administered separately. This creates challenges for families who must navigate multiple agencies and service providers. Whether federal oversight resides within the Department of Education, the Department of Health and Human Services, the Department of Justice, or another agency entirely, Virginia remains responsible for ensuring that these systems work together. For individuals and families, seamless support matters far more than organizational structure.

What Can We Do Now?
While federal agencies, courts, and policymakers continue debating legal interpretations and administrative structures, meaningful work can happen today.
For Parents and Family Caregivers
- Share your experiences with your local policymakers and advisory councils.
- Participate in public comment opportunities when they become available.
- Learn about transition planning well before adulthood.
- Build relationships with providers before a crisis occurs.
- Help identify service gaps that affect families in your community.
Your lived experience provides valuable insight into how systems are functioning.
For Service Providers
- Strengthen partnerships across healthcare, education, behavioral health, and social services.
- Invest in workforce development and staff retention; this helps to combat the staffing crisis.
- Expand person-centered practices that promote individual choice.
- Share outcome data that demonstrates what is working.
- Help policymakers understand implementation challenges.
Strong systems depend on providers who collaborate beyond organizational boundaries.
For Advocates and Community Organizations
- Promote constructive dialogue among stakeholders with differing perspectives.
- Elevate the voices of self-advocates and families.
- Focus on outcomes rather than political divisions.
- Support solutions that address both community inclusion and complex support needs.
- Educate families about available resources and services.
The most effective advocacy often occurs when stakeholders find common ground.
For Legislators and Policymakers
- Continue investing in workforce development initiatives.
- Strengthen school-to-adulthood transition services.
- Improve coordination across education, healthcare, behavioral health, and social service systems.
- Evaluate gaps across the continuum of care.
- Support data-driven policies that improve outcomes for individuals and families.
- Continue investing in crisis response, waiver services, employment supports, and community-based resources.
Most importantly, engage directly with the individuals and families who rely on these systems every day.
The debates surrounding the DOJ memorandum and the recent federal education oversight changes will continue. Those discussions are important, but they should not distract us from the larger goal. Individuals with disabilities deserve opportunities to learn, work, build relationships, participate in their communities, and pursue lives that reflect their own goals and aspirations. Families deserve systems that are accessible, coordinated, and responsive. Providers deserve the workforce investments and infrastructure necessary to deliver high-quality services. All states have a responsibility to build systems capable of supporting all three. Virginia is responsible for maintaining and improving the systems we possess that support all three.
Federal agencies may change.
Legal interpretations may change.
Administrative structures may change.
Virginia’s responsibility to build a coordinated, person-centered system of support does not.
That responsibility, and the outcomes it produces for individuals with disabilities and their families, should remain at the center of every disability policy conversation.













