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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3/20/20  12:52 pm
Commenter: Helen Trent

Live-ins, DMAS salaries, stakeholder meetings

It is very hard for someone working at DMAS making over $150,000 a year, government salaried (typically 40 hours), with all benefits to understand that requiring a person to clock in and out at specific times in their residence is not easy.  That is why everyone should have been involved in the decision making regarding EVV including those required to use it, not just those with comfortable salaries and healthy, able bodied loved ones.  The majority of persons being required to use it did not find out about it until fall 2019. There were no stakeholder meetings involving the very persons who are subjected to having to use EVV. 

We are only "able-bodied" temporarily.  Disability happens to all. 

Would those making a comfortable 150K plus per year want these live-in conditions for themselves if their loved one became disabled? :  $9/hour, no job security, no benefits, no paid sick days, no paid holidays,  no career track, pay for all transportation into the community with that $9/hour, beg a loved one or friend to be an EOR voluntarily, ask the EOR to submit their socials voluntarily,  24 hours on-call, remembering medical routines, worry constantly that the EOR will quit, worry incessantly about getting sick and not being there, have two government funded home visits a month subjecting their home to scrutiny, etc...?

Now add to all that being tied to a timed device because of EVV every single day of their lives.  This isn't a situation where you are coming or "visiting" a job and you can clock in coming and clock out going - this isn't McDonald's.  You live there.  You must constantly watch the clock, so that you can clock in and out even though you are on call 24 hours a day and you work more than the set of hours given as a live-in.  Your home should be your sanctuary, not an office or a space where you are subject to constant worry about the clock.  You worry you will forgot and there will be no pay, wrong pay, loss of services,  etc....  You worry you will spend your whole day straightening out payroll issues as a result of EVV.  You worry your power will go out.  You worry your device will be lost.  You worry the device will break.  You worry about being tracked at a minimum of twice a day.  You worry about where all this information about you and your location/habits is going. 

To think all the trouble of EVV for live-ins could be exempted and is exempted at the Federal level, and the state chose to include live-ins is unbelievable. To know that decision was made without consulting all stakeholders by those making salaries that are within the top 5% of the nation's government salaries is unconscionable.

 Exempt Live-ins. 

CommentID: 79990