Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
chapter
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
spacer
Previous Comment     Next Comment     Back to List of Comments
2/17/20  6:57 pm
Commenter: concerned about our people

What It Is and What It Does to Our People
 

Electronic Visit Verification (EVV) 

What It Is and What It Does to Our People

Disabled people and senior citizens that need help in their home for personal care, nursing services or homemaker skills have very limited options in paying for this care in America. Medicaid is the primary payer of home health care and personal care services, which means consumers live in poverty in order to qualify for the program.

Personal care services include assistance with activities of daily living such as bathing, dressing or grooming. Nursing services may cover tasks that include tracheostomy suctioning, monitoring vitals or catheterization. Light housekeeping, meal preparation or laundry assistance are examples of homemaker skills. In December 2016, private technology companies successfully lobbied Congress to include a requirement that their product be used in all home health care and personal care service visits paid by Medicaid. This product is called Electronic Visit Verification (EVV). The law is called the 21st Century Cures Act.

?The Cures Act requires EVV systems capture six pieces of information:the type of service provided (home health care or personal care service);the person receiving the service (consumer);the person providing the service (provider);the date of the service;the location where the service was provided; andthe time the service begins and ends

?EVV is an electronic method to verify that home care providers arrived to or left the consumer's home on time. The belief is that all home care services and personal care services are provided at the consumer's residence and on a schedule determined by an agency supervisor days or weeks in advance. If technology can guarantee that a provider was physically present at the home during the scheduled time, the necessary help consumers needed must have been completed. But there are a number of problems with this belief and the use of the technology.Home care services and personal care services are not always provided in the home. Most EVV technologies use GPS and/or biometric data collection to track and verify location and individuals involved. This is a violation of the Fourth Amendment Right to Privacy.Some EVV technologies use geofencing, which prohibits providers and consumers from leaving the consumer's home. This forces people to be home bound. Most EVV systems check provider visits against a pre-set schedule. But not all services are scheduled in advance and, in some instances, the consumer and not an agency supervisor sets the provider's schedule. Technologies fail. Sometimes EVV just isn't working. In many cases, consumers don't have access to Internet, phone lines or mobile devices due to cost, rural communities or because they aren't at their home.  Consumers cannot afford the costs of EVV technologies and maintenance. Even though the government says consumers shouldn't have a cost to EVV, the reality is that many consumers are required to purchase and maintain expensive mobile devices, computers or telephone lines. Sometimes providers are required to purchase these technologies. However, these costs are usually transferred to the consumer. Hidden costs of EVV include electricity increases for charging devices and Internet connectivity. These add up for people who live primarily on a fixed income and are required to live in poverty to qualify for Medicaid. Personal care services are some of the lowest paying jobs in the country. Most providers live in poverty, as well, and cannot afford to lose or skip a paycheck.

CommentID: 79141