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  4:43 pm
Commenter: Diane Coyle

Stop EVV for Live In Providers

Please eliminate the EVV requirement for Consumer Directed Services, in particular for live-in providers.  We were not given an option so we started using the EVV app, CellTrak in Fall 2019.  It has been a nightmare.  Many days the app doesn't work.  When it does work, it is difficult and cumbersome to use.  The expectation that my son's live-in caregiver, his father, has to clock in and out multiple times per day to record "shifts" is ridiculous.  With Companion Care services he can only record a max of 8 hours per day (per DMAS Service Authorization).  Do you have any idea how difficult it is to get the app to record 8 hours exactly?  Impossible.  If he records 8 hours and 1 minute, he is in violation of the service authorization.  However, if he adjusts the time to 8 hours even using the portal, he is in violation of EVV and has to explain the "error" by choosing one of several drop down options which place blame on the caregiver.  There is no option to say that the app doesn't match the service authorization or that the app is difficult to use.  Also, when I fixed another "error", I received and email from CDCN telling me that if there are too many we run the risk of either losing services or requiring re-education.  I know how to record 8 hours/day -- had NO trouble when using the portal.  The app is the problem and makes us appear to be non-complaint.  AND, even better, before CDCN started rounding time, if the app recorded 8.01 or 8.03 hours/day, at the end of the 2 week period that sum exceeded 112 hours (regardless of how small an overage), then an entire shift was not paid.  In the last example, the sum was 112.32 hours (sum of minor overages for each day totalling 19 minutes, that is 1.9 minutes per day over) so CDCN did not pay the caregiver for a full 8 hour shift.  The system is not even smart enough to recognize minor overages.  But now, CDCN is rounding hours on the portal but not on the app -- so guess what?  More challenge in trying to figure out what hours have been recorded.  Recently, caregiver recorded 3 shifts; app showed 8 hours on the phone.  BUT, portal showed 8.25 because the portal rounded the hours in each individual shift causing an overrun in error.  There is no need for this insanity.  Let live-in providers go back to using the portal.  It used to take us a quick 5 minutes to enter a days time.  There was no fraud, there was no need to know where the service was provided, there were no bogus "errors".  EVV is causing problem that never existed and I can't imagine there is any benefit to it at all.  STOP EVV FOR LIVE-IN PROVIDERS!!!

CommentID: 78936