Government-sponsored programs offering consumer direction and consumer choice in personal assistance services are not a new or unusual concept. The largest state program, the California In-Home Supportive Services Program, which “accounts for slightly over half of all the estimated participants in consumer-directed programs nationwide,” has been in existence for almost thirty years. As of 2002, “One-hundred thirty-nine . . . programs offering consumer-directed home and community-based (HCB) support services were identified [nationwide],” and these programs served an estimated 468,000 individuals. However, three factors are likely to result in a dramatic increase in consumer-directed services in the next few years, an increase that warrants a closer look at the legal issues related to such services, including the subject of this Article: liability issues related to consumer direction.