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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3/19/20  2:02 pm
Commenter: Trish Thomason


I am a parent of a disabled adult, an attendant, a previous EOR, a service facilitator, and my main job-Fiscal Agent TroubleShooter!

1.App ready?- How is it that policy is established without allowing for processing of new policies and actions to be put in place (IN WORKING ORDER) prior to the start date? How are the Fiscal Agents not mandated to be IN WORKING ORDER PRIOR to start date? How are technical requirements of the legislative policy not mandated to be proven to be in working order WITH fail-safe corrections or troubleshooting processes not be mandated to be in place? How are the Fiscal Agents not mandated to be prepared for possible issues that may arise when putting in a completely new process? How can the Fiscal Agent's IT/Tech departments NOT be available to the consumer/EOR/Attendant so that issues can be resolved? The questions are never-ending. Federal Policy was written and mandated giving the states the ability to individualize the program designs to guide the Federal Policy within their respective states. States don't have to reinvent the wheel. They just need to do some leg-work, make some phone calls and see what works best. If you are going to mandate that your state citizens MUST abide by the rules or be fined or face legal action, then I suggest you also mandate that the Fiscal Agents you approve to work in the state with Medicaid MUST abide by the same rules. The threat to the public who are just trying to work WITHIN your expectations should be felt and acted on to ALL parties involved in the policy that you made law.

2. EVV- I believe there needs to be more common sense put in decisions when you create policies that the disabled community and the people working in that community. First of all, these are disabled individuals and their support system. I understand that our culture is one that decides when a few break the rules (or more often than not, make mistakes), then the masses must comply to rules to prevent rule-breaking. Are the lives and challenges that the disabled community deal with daily, taken into consideration at all? The disabled members and their support system often have ten-fold more paperwork to complete to "prove" they are disabled. Most all ADL and IADL tasks require 2,3, even 5 times the amount of time it can take abled individuals. The disabled must wait for weeks and months to clear up problems in the red-tape world. Now, it's been decided that we should also spend time repairing apps, time sheets, be on hold for hours, hope for a call back from F/EA, hope that attendants will still work even if they don't get paid for 6-8 weeks or longer. If you want to put an app in place-then the app should WORK! If you want to manage that app-then the F/EA should answer the phone! If you demand that the policy is in place-then make sure the program works PRIOR to the start date.

3. Fiscal Agent selection- Cheaper is not always better. You have selected CDCN which can not handle the client load, phone load, the people in Montana can't do anything in the VA system so they refer us to voice mail. The reps who answer often have to "look at their book". There's one phone number for the entire country to use to reach them. They do not offer evening or Saturday hours. Many PCG's and EOR's work all day long but they are the parties that CDCN wants to speak with. Why is it that everything app related is "tech issue" and they have to send "the flag" to tech. We as the attendant can't talk to tech, but the customer service rep also can't talk to tech. So we are left to "HOPE" that the rep wrote the correct thing and "HOPE" that a tech person gets it, but there is no feedback as to the result much of the time. Sometimes they do call or email with a response-but VERY RARELY!

4. EVV not mandatory for live-in attendants-Is it possible to consider the policy that other states have implemented which states that if the attendant lives in the home or is a family member, then they can use the web portal to submit times. For many of us, our members have emergencies or our care does not run on an exact schedule and it's very easy to forget to sign in and out. Our priority is the safety and health of our client, not signing in and out. 

Please consider putting the burden of the law being put in place on ALL parties-to include the F/EA. If attendants are trying to follow the rules but can't and they work without pay for weeks/months,  then the F/EA should have a fund to pay the attendants so that people don't lose their home because Cell-Trak doesn't work for weeks which leads to someone not being paid. Our labor laws state that if a person works, they should get paid according to the contract. Medicaid and F/EA's are breaking the contract by NOT paying attendants who have worked-- and all because Medicaid and F/EA's institutions do not have the tech, support, policies, staffing to do their job correctly.

5. Why exactly haven't the states gotten together and sued the federal government over the issue of tracking the disabled like that.  This is a human rights violation. 
CommentID: 79892