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  5:46 pm
Commenter: Elaine Geer

Do not cripple those with disabilities with EVV
Do not cripple those with disabilities with EVV

"Person centered planning requires really listening to the person" DMAS stated this and yet they are not listening to the person about EVV!  

Do not say persons are not being tracked when they are providing location at least twice a day.  A minimum of two clock ins and outs a day over a period of time produces documentation of habits.  No one wants their daily lives and their habits tracked.  No one.  To have live-ins do this, is essentially having their lives tracked.  It is an invasion of privacy.  

Live ins were found exempt by CMS.  Virginia chose to include live-ins. However, many agencies in Virginia are still stating that live-ins are part of the Federal Mandate.  That spreading of disinformation must stop. 

The Cures Act states EVV is for "visits".  The name is titled Electronic Visit Verification.  Live-ins do not visit.  Their job is 24 hours a day and yet they are given a set of arbitrary hours to clock in and out to.  It is nearly impossible to clock in and out at set times when a person is providing 24 hour care.  The clock becomes more important than the person cared for in a situation like this.  The last thing a good caregiver wants to do is let down the person they care for, but the state is making a live-in's job so difficult, that they may be forced to quit.  Institutionalization will be the ONLY option at that point. 

With the majority of live-ins receiving two in-home visits per month and countless ongoing evaluations, how much oversight is enough?

The waiver program was put into place to allow independence and community access to persons with disabilities.  EVV is a grand hinderance to partaking and enjoying community access.  Do not say they can go anywhere with the app and clock in and out!  When folks are stuck home dealing with the app, the bureaucracy, and fallout EVV causes, they are NOT in the community!  Crippling the disabled by making it more difficult to maneuver their daily lives is not an option.  

This is the lowest cost care available to the state and it is being eroded by EVV.  



EVV has created unnecessary burdens and additional bureacracy just to CLOCK IN AND OUT.  This is not a simple clock in and out procedure. There is always some difficulty with EVV which can be attested to simply by using a search engine and reading complaints readily available online.  Letters have been written to many state officials as well concerning this cumbersome, burdensome process.   

CommentID: 80023