Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
Standards Established and Methods Used to Assure High Quality Care [12 VAC 30 ‑ 60]
Action Electronic Visit Verification
Stage Proposed
Comment Period Ended on 3/21/2020
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1/25/20  1:20 pm
Commenter: T Burns

Exempt Consumer Directed Services from EVV
I am begging VA legislators and Governor to help fix this disaster we call EVV.
VA's needs to exempt Consumer Directed Waiver Services from having to use EVV.  Agency directed can continue to use it, but families and individuals using Consumer Directed Services should be exempt from this requirement.

The 21st Century Cures Act does NOT define "location" in its legislation. The VA legislature  added a GPS tracking mandate to EVV and also biometrics. No other citizen group in VA is required to be GPS tracked to receive services they have qualified and are eligible for. This treast individuals with disabilities as 2nd Class Citizens who don't warrant protection and privacy

The APPS that families and caregivers are required to use are full of glitches and many times do not work correctly.  My son's attendants have to edit times all of the time because the APP either does not keep accurate times, or just will not work. Each time there has to be a manual edit, there is a message threatening services for my adult son with autism.

EVV threatens decades of the work to create a more independent life for individuals with disabilities. EVV has no place in Personal Care Services or Consumer-Directed Services, or in waiver programs that offer consumer directed-like options. While some states refer to their programs by differing names, consumer directed programs provide our son with: choice of service provider; location of service (home or community); scheduling responsibilities; and consumer control

The Federal mandates in the 21st Century Cares act can be met by utilizing the system that was already in place (web portal and print time sheets) and added a space within each of those to indicate location of services.  No app, no gps, no biometrics are required. 

There is already oversight put into place for these services.  At least once a year my son has to be evaluated to determine he still qualifies for services and to see what his needs are.  A proposal for the number of allowed hours and types of care are sent to the state for approval.  After hours/services are approved, a case manager and a service facilitator both check in monthly on those hours and services.  In addition when someone submits a timesheet, I as the Employer of Record would approve those hours as well.  EVV just adds to this and is a burden to families and attendants. 

The federal EVV mandate, was not created because of the need to eliminate fraud in Medicaid personal care services. In fact studies show that most of the "fraud" issues come from agencies and not individuals getting paid $9.44 an hour prior to taxes.  Consumer Directed Services need to be exempt from this system.

CommentID: 78934