| Action | Elderly or Disabled with Consumer Direction Waiver Updates |
| Stage | Proposed |
| Comment Period | Ended on 12/7/2012 |
 |
36 comments
There should be clear verbiage as to the approval of electronic medical records for the EDCD waiver instead of just mentioning the Aide record........The use of ATL for aides to call in and out from patients home # as well as to enter his/her tasks.
12VAC120 Waiver Services
We are in general agreement that revision of these regulations is long overdue. In many cases, the regulations are in conflict with current best practice standards and are inconsistently applied to a variety of programs that have been consolidated. For example:
Remove the proposed regulation that requires that providers obtain a professional reference for an nurse aide applicant who has only worked for 1 employer. Providers have found that many employers are unresponsive to reference requests. The requirement will eliminate a percentage of potentials qualified workers because of the inability to get a response from a former employer. Given the shortage of nurse aides this would further limit the pool of potential workers need to cover cases. We ask that personal references continue to be allowed.
Remove the requirement that nurse aides "physically attend" 12 hours of in-service education anually.Providers should be allowed to continue to utilize printed material and other mediums.It is effective and sufficient to require RN supervisors provide instruction in the home during home visits when nurse aide deficiencies in knowledge are identified that are recipient specific.
Remove the requirement that signatures times and dates be placed on the record no later than 7 calendar days from the last date of service. In many cases it will be impossible to comply with standard, and in cases in which the signature cannot be obtained in this time frame, there is no remedy for the provider preventing the provider from the ability to bill for services that were appropriately rendered. For example, the client is hospitalized or leaves town without notice and doesn't return home for many weeks. There are many other examples providers can give in which it takes many week and longer to obtain a signature from a recipient.
I run a 102 bed assisted living in extreme Southwest Virginia.I have ran this for 20 years.
We have a large population of poorer residents in our facility.The current rate for the poor is around $38.00 per day.The cost to provide this service is around $50.00 per day.The program that funds this is called auxiliary grant.This comes directly out of the general fund.The general assembly and government are totally aware of the rate and refuse to supplement the cost to at least a break even.Virgiinia desperately need to increase the rate for the poor.The poorer in general are more care intensive.Why is it Virginia does not get with it and include assisted living for waiver services.This would help offset a significant increase as the federal government would pay 50%.Assisted Living provides around the clock personal care Currently the auxiliary grant rate is $1.59 cents an hour.Medicaid personal care waiver program rates range $13-15 per hour,maybe a little more maybe a little less.Seems like double the rate for a assisted living waiver for disabled would be a good better value to the state.Let me make myself perfectly clear.WHY IS THE VIRGINIA POLITICIANS SO DEDICATED TO SATISFY SPECIAL PACS OR POLITICAL ACTION COMMITTEES AND REFUSE TO FUND A WORTHWHILE SERVICE IN ASSISTED LIVING FOR THE POOR.WHY WHY WHY ,CAN ANYONE ANSER THAT?
I feel strongly that an existing RN who has 1 yr. of experience is fully capable to manage personal care clients at any level. registerered nurses after having graduated school, and passing their Boards and working out in the field of their choice are indeed worthy, as well as capable to work with personal care clients. At the time of their hire, their prospective employer should have gained understanding of their worthiness to fulfill the job requirements they are seeking to have filled. Also. it is up to the employer to provide adequate training to support the RN of their choice to grow and develop in their management of personal care clients.
I disagree strongly that personal care aides should be required to attend 12 hr. of yearly inservice training. The monthly handouts that are given to them have been developed at a level for them to support their work with our clients, and are fully developed at a level they can understand. each handout is often illusratated, and is followed with a basic test that allows us to know that they have indeed understood the material given to them. Their lives are often hectic as many of them are single parents burdened with the everyday care of their families, and this allows them to complete inservices in their own time, and return them in a timely manner.I have found these inservices to be so well developed, that I frequently use them in the personal care classes that I teach , which has proven to be an invaluable support tool to insure that they get everything I can offer them prior to completing Care advantages Personal Care Program.
i personally feel that if I as an RN admit a client that an RN should perform all supervisory visits. it would not be enough for me to only lay eyes on any patient that I am casemanaging every 6 months. I prefer to follow the clients that I am responsible for I also feel that it provides better continuity of service to our clients who often have to deal with changes with their personal care aides for one reason or another. I must say here that all nurses are not created equal. while having been an LPN myself at one time, i went back to school to grow and develop as a nurse for many reasons.
I also feel STRONGLY that all sup visits should NOT be reduced to every 90 days. as an RN I feel and know in my heart that conitively impaired individuals who cannot speak for themselves, need and deserve a visit form their RN case manager. That is the very least that we owe the clients that we are responsible for ...decisions such as this cannot, and should not be made with only business reasons in mind!!!!!!!!!!
We recommend that provision be made to insure providers, case managers and coordinators realize that there are no automatic renewals of service authorizations. Providers need to submit clinical documentation of medical necessity prior to the expiration of service authorizations to insure continuity.
I feel that personal care aides should not be required to physically attend a 12 hour annual training program. The hand outs given monthly, which also include a comprehension test are more than sufficient as far as evaluating their understanding of the services in which they are providing. The personal care aides have completed what is required for them to become licensed and have proved their ability to care for others, which is the reason they were hired. Pulling them from the field where they're gaining the ultimate knowledge, hands on experience, would not be in the best interest of all those involved. The hand outs allow them to complete the training on their own time, before the due date, also allowing the upmost comprehension because they are choosing when to engage in the information and the pace in which they are doing so. With them making that decision, it is more likely that they will better absorb the information.
I agree fully that an RN with 1 year of clinical nursing experience is fully capable of upholding the position and managing personal care clients. The schooling in which registered nurses complete as well as the capability of that nurse to pass the boards, prove that they have comprehended what is asked of them as a care provider of that level. The one year of experience following the passing of their boards allows the nurse to put to use what they have learned and is certainly a sufficient amount of time to polish the skills and develop themselves as a registered nurse. Upon being hired, the company will also supply adequate training to ensure that they are fully capable of upholding the position in which they are assigned.
proposed regulations for the ECDC waver
Remove the proposed regulation that requires that providers obtain a professional reference for a nurse aide applicant who has only worked for 1 employer. Providers have found that many employers are unresponsive to reference requests. The requirement will eliminate a percentage of potentially qualified workers because of the inability to get a response from a former employer. Given the shortage of nurse aides this would further limit the pool of potential workers needed to cover cases. We ask that personal references continue to be allowed.
Remove the requirement that nurse aides "physically attend" 12 hours of in-service education anually.Providers should be allowed to continue to utilize printed material and other mediums. It is effective and sufficient to require RN supervisors provide instruction in the home during home visits when nurse aide deficiencies in knowledge are identified that are recipient specific.
Remove the requirement that signatures times and dates be placed on the record no later than 7 calendar days from the last date of service. In many cases it will be impossible to comply with standard, and in cases in which the signature cannot be obtained in this time frame, there is no remedy for the provider preventing the provider from the ability to bill for services that were appropriately rendered. For example, the client is hospitalized or leaves town without notice and doesn't return home for many weeks. There are many other examples providers can give in which it takes many weeks and longer to obtain a signature from a recipient.
Sincerely,
Bill Hurt
Senior Corporate Manager
AmeriCare Plus
Remove the proposed regulation that requires that providers obtain a professional reference for a nurse aide applicant who has only worked for 1 employer. Providers have found that many employers are unresponsive to reference requests. The requirement will eliminate a percentage of potentially qualified workers because of the inability to get a response from a former employer. Given the shortage of nurse aides this would further limit the pool of potential workers needed to cover cases. We ask that personal references continue to be allowed.
Remove the requirement that nurse aides "physically attend" 12 hours of in-service education anually.Providers should be allowed to continue to utilize printed material and other mediums. It is effective and sufficient to require RN supervisors provide instruction in the home during home visits when nurse aide deficiencies in knowledge are identified that are recipient specific.
Remove the requirement that signatures times and dates be placed on the record no later than 7 calendar days from the last date of service. In many cases it will be impossible to comply with standard, and in cases in which the signature cannot be obtained in this time frame, there is no remedy for the provider preventing the provider from the ability to bill for services that were appropriately rendered. For example, the client is hospitalized or leaves town without notice and doesn't return home for many weeks. There are many other examples providers can give in which it takes many weeks and longer to obtain a signature from a recipient.
Sincerely,
Shelby Smith
AmeriCare Plus
Remove the proposed regulation that requires that providers obtain a professional reference for a nurse aide applicant who has only worked for 1 employer. Providers have found that many employers are unresponsive to reference requests. The requirement will eliminate a percentage of potentially qualified workers because of the inability to get a response from a former employer. Given the shortage of nurse aides this would further limit the pool of potential workers needed to cover cases. We ask that personal references continue to be allowed.
Remove the requirement that nurse aides "physically attend" 12 hours of in-service education anually.Providers should be allowed to continue to utilize printed material and other mediums. It is effective and sufficient to require RN supervisors provide instruction in the home during home visits when nurse aide deficiencies in knowledge are identified that are recipient specific.
Remove the requirement that signatures times and dates be placed on the record no later than 7 calendar days from the last date of service. In many cases it will be impossible to comply with standard, and in cases in which the signature cannot be obtained in this time frame, there is no remedy for the provider preventing the provider from the ability to bill for services that were appropriately rendered. For example, the client is hospitalized or leaves town without notice and doesn't return home for many weeks. There are many other examples providers can give in which it takes many weeks and longer to obtain a signature from a recipient.
12VAC30-120-900 Definitions
Employer of record
Revise the definition to maintain the current practice of allowing the employer of record (EOR) to be a family member, caregiver or other person chosen by the individual.
Guardian
Revise the definition to clarify that guardianship decision making authority could be limited and not include all of the decision items listed at the end of this definition. This could be accomplished by adding “/or” before the last word in the definition.
Preadmission screening
The proposed regulations add “for long term care services” to item (i). Preadmission screening as described in this definition does not include screening for all long term care services. The proposed regulation should specify preadmission screening is for the Alzheimer’s, EDCD and Tech Waivers, PACE and nursing facilities.
Add a statement that the screening process includes the provision of a description of agency-directed and consumer-directed services to ensure that individuals are making informed choices.
Primary caregiver
Clarify the regulation to reflect that not all individuals will have a primary caregiver, that there is no requirement to have a primary caregiver, and that documentation of a primary caregiver is not required.
Prior authorization, Service authorization
The proposed definition states that prior authorization would be required before a service “is rendered or reimbursed”. Several services are not authorized prior to the service before provided. For example, transition coordination is provided during the day of enrollment into Money Follows the Person. However, the service is not approved (authorized) before the service is provided. The request for prior authorization is requested the day of service, but the service authorization does not occur before the service is rendered.
12VAC30-120-905 Waiver description and legal authority
E. The proposed regulation would require prior authorization when services are provided outside of the Commonwealth, except for brief illnesses or vacations. This new requirement is unnecessary so long as the services continue to be needed as documented on the plan of care and the total number of service hours does not change.
12VAC30-120-920 Individual eligibility requirements
C.2. Insert “for people 55 years of age or older” before PACE to clarify that PACE is not available to younger people.
C.9. Clarify that transition coordination and transition services can be provided to an individual while they reside in a Psychiatric Residential Treatment Facility, so long as the individual meets other Money Follows the Person eligibility criteria.
D.1. Revise the last sentence in this item to read: “Individuals unable to or who elect not to manage their own care may have a family member, caregiver or designated person of their choice serve as the EOR on their behalf.” Current regulation does not limit others from the list of people the individual can have act on their behalf as the EOR. The proposed regulation assumes that the only people who may want or need to have someone act as their EOR are people who have cognitive impairments.
12VAC30-120-924 Covered services: limits on covered services
B.1.c. Amend the proposed regulation by adding at the end of the sentence: “or other service”. As drafted, the proposed regulation would prohibit individuals from beginning or continuing consumer-directed (CD) services even if the individual’s medical or behavioral needs could be met by another service. For example, Medicaid State Plan home health benefits could provide skilled services for the individual’s nursing needs. The skilled services would not “be met through CD services”, yet the skilled services could still be provided.
D.1. Add a new item d to require “The agency document the waiver individual’s choice of the agency model.” A similar requirement is in the proposed regulation at F.1. for services facilitation.
D.2.b. (3) Supervision should be permitted in work or postsecondary schools if the supervision is not being provided as a reasonable accommodation as part of the Americans with Disabilities Act or the Rehabilitation Act. (This comment also applies to 12VAC30-120-924 G.3.c.)
F.1. Delete “waiver individual and family/caregiver” from the third sentence in this item. The training should be provided to the EOR.
H.4.b. Replace “Chapter 790 of the 2010 Acts of Assembly” with “54.1-2901.A.32”. This more specific citation provides information needed to implement this option when appropriate.
12VAC30-120-930 General requirements for home and community-based participating providers
I. The proposed regulation omits language describing the required knowledge, skills and abilities for services facilitators. The description of required knowledge, skills and abilities in the current regulations should be maintained in the new regulations.
I.4.c.(8) and I.5.i. The proposed reference to TB screening states that screening should be “as specified in the criteria used by the VDH.” The document or citation for the specific required criteria should be included in this regulation.
12VAC30-120-935 Participation standards for specific covered services
H.3.b. The proposed regulation regarding personal care would require a “face-to-face meeting with the waiver individual and family/caregiver”. The regulation should not require the family/caregiver and services facilitator to meet face-to face. Sufficient information can be gathered by the services facilitator by meeting with the waiver individual face-to-face and then speaking with the individual or family caregiver by telephone. Some families prefer this manner of meeting to minimize their time away from their jobs.
The last sentence of this item addresses review visits for respite. The proposed regulation states that the face-to-face meeting could be “with the individual or family/caregiver, or both.” It is important to maintain the current requirement for the meeting with the individual to be face-to-face.
H.3.c.(3) The services facilitator would be required to include in their meeting summary information about “special tasks performed by the attendant”. The regulation should describe “special tasks”.
H.4. Add that the results of the check of records by a local DSS to determine if the attendant has been found to have abused, neglected, or exploited an adult 60 year of age or older or an adult who is 18 years of age or older who is also incapacitated should be reported to the EOR.
H.4. The end of this sentence requires that the findings of records checks to be reported to the waiver individual or the family/caregiver or EOR. This should be changed to require the information be provided to the EOR.
H.6.b. References to the “POC goals, objectives, and activities” should be omitted from the regulation. Goals, objectives and activities are not a part of EDCD Waiver services facilitation.
H.10.a. The fourth sentence should be modified to state “Waiver individuals unable to or who elect not to manage their own care may have a family member, caregiver or designated person of their choice serve as the EOR on their behalf.”
12VAC30-120-945 Payment for covered services
B.5.a. The last sentence in this item should be changed to clarify that if the individual switches to another waiver that offers AT, the individual will have access to needed AT according to the limits in the new waiver. The exception would be if the individual has already used the maximum allowable amount for AT during the year of MFP enrollment, they then would not have access to AT in the new waiver for one year.
The Virginia Board for People with Disabilities (VBPD), Virginia's Developmental Disabilities Council supports the comments submitted by the Virginia Association of Centers for Independent Living (VACIL) below.
12VAC30-120-900 Definitions
Employer of record
Revise the definition to maintain the current practice of allowing the employer of record (EOR) to be a family member, caregiver or other person chosen by the individual.
Guardian
Revise the definition to clarify that guardianship decision making authority could be limited and not include all of the decision items listed at the end of this definition. This could be accomplished by adding “/or” before the last word in the definition.
Preadmission screening
The proposed regulations add “for long term care services” to item (i). Preadmission screening as described in this definition does not include screening for all long term care services. The proposed regulation should specify preadmission screening is for the Alzheimer’s, EDCD and Tech Waivers, PACE and nursing facilities.
Add a statement that the screening process includes the provision of a description of agency-directed and consumer-directed services to ensure that individuals are making informed choices.
Primary caregiver
Clarify the regulation to reflect that not all individuals will have a primary caregiver, that there is no requirement to have a primary caregiver, and that documentation of a primary caregiver is not required.
Prior authorization
Service authorization
The proposed definition states that prior authorization would be required before a service “is rendered or reimbursed”. Several services are not authorized prior to the service before provided. For example, transition coordination is provided during the day of enrollment into Money Follows the Person. However, the service is not approved (authorized) before the service is provided. The request for prior authorization is requested the day of service, but the service authorization does not occur before the service is rendered.
12VAC30-120-905 Waiver description and legal authority
E. The proposed regulation would require prior authorization when services are provided outside of the Commonwealth, except for brief illnesses or vacations. This new requirement is unnecessary so long as the services continue to be needed as documented on the plan of care and the total number of service hours does not change.
12VAC30-120-920 Individual eligibility requirements
C.2. Insert “for people 55 years of age or older” before PACE to clarify that PACE is not available to younger people.
C.9. Clarify that transition coordination and transition services can be provided to an individual while they reside in a Psychiatric Residential Treatment Facility, so long as the individual meets other Money Follows the Person eligibility criteria.
D.1. Revise the last sentence in this item to read: “Individuals unable to or who elect not to manage their own care may have a family member, caregiver or designated person of their choice serve as the EOR on their behalf.” Current regulation does not limit others from the list of people the individual can have act on their behalf as the EOR. The proposed regulation assumes that the only people who may want or need to have someone act as their EOR are people who have cognitive impairments.
12VAC30-120-924 Covered services: limits on covered services
B.1.c. Amend the proposed regulation by adding at the end of the sentence: “or other service”. As drafted, the proposed regulation would prohibit individuals from beginning or continuing consumer-directed (CD) services even if the individual’s medical or behavioral needs could be met by another service. For example, Medicaid State Plan home health benefits could provide skilled services for the individual’s nursing needs. The skilled services would not “be met through CD services”, yet the skilled services could still be provided.
D.1. Add a new item d to require “The agency document the waiver individual’s choice of the agency model.” A similar requirement is in the proposed regulation at F.1. for services facilitation.
D.2.b. (3) Supervision should be permitted in work or postsecondary schools if the supervision is not being provided as a reasonable accommodation as part of the Americans with Disabilities Act or the Rehabilitation Act. (This comment also applies to 12VAC30-120-924 G.3.c.)
F.1. Delete “waiver individual and family/caregiver” from the third sentence in this item. The training should be provided to the EOR.
H.4.b. Replace “Chapter 790 of the 2010 Acts of Assembly” with “54.1-2901.A.32”. This more specific citation provides information needed to implement this option when appropriate.
12VAC30-120-930 General requirements for home and community-based participating providers
I. The proposed regulation omits language describing the required knowledge, skills and abilities for services facilitators. The description of required knowledge, skills and abilities in the current regulations should be maintained in the new regulations.
I.4.c.(8) and I.5.i. The proposed reference to TB screening states that screening should be “as specified in the criteria used by the VDH.” The document or citation for the specific required criteria should be included in this regulation.
12VAC30-120-935 Participation standards for specific covered services
H.3.b. The proposed regulation regarding personal care would require a “face-to-face meeting with the waiver individual and family/caregiver”. The regulation should not require the family/caregiver and services facilitator to meet face-to face. Sufficient information can be gathered by the services facilitator by meeting with the waiver individual face-to-face and then speaking with the individual or family caregiver by telephone. Some families prefer this manner of meeting to minimize their time away from their jobs.
The last sentence of this item addresses review visits for respite. The proposed regulation states that the face-to-face meeting could be “with the individual or family/caregiver, or both.” It is important to maintain the current requirement for the meeting with the individual to be face-to-face.
H.3.c.(3) The services facilitator would be required to include in their meeting summary information about “special tasks performed by the attendant”. The regulation should describe “special tasks”.
H.4. Add that the results of the check of records by a local DSS to determine if the attendant has been found to have abused, neglected, or exploited an adult 60 year of age or older or an adult who is 18 years of age or older who is also incapacitated should be reported to the EOR.
H.4. The end of this sentence requires that the findings of records checks to be reported to the waiver individual or the family/caregiver or EOR. This should be changed to require the information be provided to the EOR.
H.6.b. References to the “POC goals, objectives, and activities” should be omitted from the regulation. Goals, objectives and activities are not a part of EDCD Waiver services facilitation.
H.10.a. The fourth sentence should be modified to state “Waiver individuals unable to or who elect not to manage their own care may have a family member, caregiver or designated person of their choice serve as the EOR on their behalf.”
12VAC30-120-945 Payment for covered services
B.5.a. The last sentence in this item should be changed to clarify that if the individual switches to another waiver that offers AT, the individual will have access to needed AT according to the limits in the new waiver. The exception would be if the individual has already used the maximum allowable amount for AT during the year of MFP enrollment, they then would not have access to AT in the new waiver for one year.
Please review the barrier crime statues, they are different than from those currently used.
EOR definition should be expanded to reflect current practice
EOR reference throughout should stand alone when speaking of employer responsibilities.
MFP definition should be expanded beyond transition services
Throughout the regulation, SF and providers are referenced separately, SFs are providers and therefore there is no need for the separate reference.
12VAC30-120-924
B.2..b. Please clarify that individuals that cannot assure health, safety, welfare or back-up plan is ineligible for EDCD waiver services.
3. Please clarify "timesheet discrepancies"
12VAC30-120-924
E.4.a. Respite
Current practice reflects 480 hours per FY but that does not reflect current practice of 480 per CY
F. 1. b. Why does the EOR have to maintain copies of attendant timesheets for SF review when the FEA makes all timesheet available through their webportal.
F.2.a.4. This statement is unclear
J.b. Transition services - institutions should be broadened to incorporate all qualified institutions
Remove the proposed regulation that requires that providers obtain a professional reference for a nurse aide applicant who has only worked for 1 employer. Providers have found that many employers are unresponsive to reference requests. The requirement will eliminate a percentage of potentially qualified workers because of the inability to get a response from a former employer. Given the shortage of nurse aides this would further limit the pool of potential workers needed to cover cases. We ask that personal references continue to be allowed.
Remove the requirement that nurse aides "physically attend" 12 hours of in-service education anually.Providers should be allowed to continue to utilize printed material and other mediums. It is effective and sufficient to require RN supervisors provide instruction in the home during home visits when nurse aide deficiencies in knowledge are identified that are recipient specific.
Remove the requirement that signatures times and dates be placed on the record no later than 7 calendar days from the last date of service. In many cases it will be impossible to comply with standard, and in cases in which the signature cannot be obtained in this time frame, there is no remedy for the provider preventing the provider from the ability to bill for services that were appropriately rendered. For example, the client is hospitalized or leaves town without notice and doesn't return home for many weeks. There are many other examples providers can give in which it takes many weeks and longer to obtain a signature from a recipient.
.
12VAC30-12-930
19.b. The criminal record check results should not be retained in an employees file however proof of the check should be retained.
I.4.a. Personal care agencies are all now licensed through VDH. Is this section needed?
c 4, and 5. d and though-out provider sections -What if the personal care aide does not have a social security number because they are from a different country but has a work visa?
e. Please clarify the barrier crimes COV citation additionally, please clarify if the individual has to be free of convictions from both lists.
i. What is the criteria used by VDH TB screening. This should be more specific.
2.a. Please revise the SF qualifications sections to be consistent with currently enacted regulations with the exception to require at a minimum an associates degree in a health or human service field or two years of satisfactory work experience in a human service field working with individuals who are disabled or elderly.
5. approved hours cannot be exceeded.
Remove the proposed regulation that requires that providers obtain a professional reference for a nurse aide applicant who has only worked for 1 employer. Providers have found that many employers are unresponsive to reference requests. The requirement will eliminate a percentage of potentially qualified workers because of the inability to get a response from a former employer. Given the shortage of nurse aides this would further limit the pool of potential workers needed to cover cases. We ask that personal references continue to be allowed.
Remove the requirement that nurse aides "physically attend" 12 hours of in-service education anually.Providers should be allowed to continue to utilize printed material and other mediums. It is effective and sufficient to require RN supervisors provide instruction in the home during home visits when nurse aide deficiencies in knowledge are identified that are recipient specific.
Remove the requirement that signatures times and dates be placed on the record no later than 7 calendar days from the last date of service. In many cases it will be impossible to comply with standard, and in cases in which the signature cannot be obtained in this time frame, there is no remedy for the provider preventing the provider from the ability to bill for services that were appropriately rendered. For example, the client is hospitalized or leaves town without notice and doesn't return home for many weeks. There are many other examples providers can give in which it takes many weeks and longer to obtain a signature from a recipient.
proposed regulations for the ECDC waver
Remove the proposed regulation that requires that providers obtain a professional reference for a nurse aide applicant who has only worked for 1 employer. Providers have found that many employers are unresponsive to reference requests. The requirement will eliminate a percentage of potentially qualified workers because of the inability to get a response from a former employer. Given the shortage of nurse aides this would further limit the pool of potential workers needed to cover cases. We ask that personal references continue to be allowed.
Remove the requirement that nurse aides "physically attend" 12 hours of in-service education anually.Providers should be allowed to continue to utilize printed material and other mediums. It is effective and sufficient to require RN supervisors provide instruction in the home during home visits when nurse aide deficiencies in knowledge are identified that are recipient specific.
Remove the requirement that signatures times and dates be placed on the record no later than 7 calendar days from the last date of service. In many cases it will be impossible to comply with standard, and in cases in which the signature cannot be obtained in this time frame, there is no remedy for the provider preventing the provider from the ability to bill for services that were appropriately rendered. For example, the client is hospitalized or leaves town without notice and doesn't return home for many weeks. There are many other examples providers can give in which it takes many weeks and longer to obtain a signature from a recipient.
Remove the proposed regulation that requires that providers obtain a professional reference for a nurse aide applicant who has only worked for 1 employer. Providers have found that many employers are unresponsive to reference requests. The requirement will eliminate a percentage of potentially qualified workers because of the inability to get a response from a former employer. Given the shortage of nurse aides this would further limit the pool of potential workers needed to cover cases. We ask that personal references continue to be allowed.
Remove the requirement that nurse aides "physically attend" 12 hours of in-service education anually.Providers should be allowed to continue to utilize printed material and other mediums. It is effective and sufficient to require RN supervisors provide instruction in the home during home visits when nurse aide deficiencies in knowledge are identified that are recipient specific.
Remove the requirement that signatures times and dates be placed on the record no later than 7 calendar days from the last date of service. In many cases it will be impossible to comply with standard, and in cases in which the signature cannot be obtained in this time frame, there is no remedy for the provider preventing the provider from the ability to bill for services that were appropriately rendered. For example, the client is hospitalized or leaves town without notice and doesn't return home for many weeks. There are many other examples providers can give in which it takes many weeks and longer to obtain a signature from a recipient.
Remove the proposed regulation that requires that providers obtain a professional reference for a nurse aide applicant who has only worked for 1 employer. Providers have found that many employers are unresponsive to reference requests. The requirement will eliminate a percentage of potentially qualified workers because of the inability to get a response from a former employer. Given the shortage of nurse aides this would further limit the pool of potential workers needed to cover cases. We ask that personal references continue to be allowed.
Remove the requirement that nurse aides "physically attend" 12 hours of in-service education anually.Providers should be allowed to continue to utilize printed material and other mediums. It is effective and sufficient to require RN supervisors provide instruction in the home during home visits when nurse aide deficiencies in knowledge are identified that are recipient specific.
Remove the requirement that signatures times and dates be placed on the record no later than 7 calendar days from the last date of service. In many cases it will be impossible to comply with standard, and in cases in which the signature cannot be obtained in this time frame, there is no remedy for the provider preventing the provider from the ability to bill for services that were appropriately rendered. For example, the client is hospitalized or leaves town without notice and doesn't return home for many weeks. There are many other examples providers can give in which it takes many weeks and longer to obtain a signature from a recipient.
Remove the proposed regulation that requires that providers obtain a professional reference for a nurse aide applicant who has only worked for 1 employer. Providers have found that many employers are unresponsive to reference requests. The requirement will eliminate a percentage of potentially qualified workers because of the inability to get a response from a former employer. Given the shortage of nurse aides this would further limit the pool of potential workers needed to cover cases. We ask that personal references continue to be allowed.
Remove the requirement that nurse aides "physically attend" 12 hours of in-service education anually.Providers should be allowed to continue to utilize printed material and other mediums. It is effective and sufficient to require RN supervisors provide instruction in the home during home visits when nurse aide deficiencies in knowledge are identified that are recipient specific.
Remove the requirement that signatures times and dates be placed on the record no later than 7 calendar days from the last date of service. In many cases it will be impossible to comply with standard, and in cases in which the signature cannot be obtained in this time frame, there is no remedy for the provider preventing the provider from the ability to bill for services that were appropriately rendered. For example, the client is hospitalized or leaves town without notice and doesn't return home for many weeks. There are many other examples providers can give in which it takes many weeks and longer to obtain a signature from a recipient.
proposed regulations for the ECDC waver
Remove the proposed regulation that requires that providers obtain a professional reference for a nurse aide applicant who has only worked for 1 employer. Providers have found that many employers are unresponsive to reference requests. The requirement will eliminate a percentage of potentially qualified workers because of the inability to get a response from a former employer. Given the shortage of nurse aides this would further limit the pool of potential workers needed to cover cases. We ask that personal references continue to be allowed.
Remove the requirement that nurse aides "physically attend" 12 hours of in-service education anually.Providers should be allowed to continue to utilize printed material and other mediums. It is effective and sufficient to require RN supervisors provide instruction in the home during home visits when nurse aide deficiencies in knowledge are identified that are recipient specific.
Remove the requirement that signatures times and dates be placed on the record no later than 7 calendar days from the last date of service. In many cases it will be impossible to comply with standard, and in cases in which the signature cannot be obtained in this time frame, there is no remedy for the provider preventing the provider from the ability to bill for services that were appropriately rendered. For example, the client is hospitalized or leaves town without notice and doesn't return home for many weeks. There are many other examples providers can give in which it takes many weeks and longer to obtain a signature from a recipient.
proposed regulations for the ECDC waver
Remove the proposed regulation that requires that providers obtain a professional reference for a nurse aide applicant who has only worked for 1 employer. Providers have found that many employers are unresponsive to reference requests. The requirement will eliminate a percentage of potentially qualified workers because of the inability to get a response from a former employer. Given the shortage of nurse aides this would further limit the pool of potential workers needed to cover cases. We ask that personal references continue to be allowed.
Remove the requirement that nurse aides "physically attend" 12 hours of in-service education anually.Providers should be allowed to continue to utilize printed material and other mediums. It is effective and sufficient to require RN supervisors provide instruction in the home during home visits when nurse aide deficiencies in knowledge are identified that are recipient specific.
Remove the requirement that signatures times and dates be placed on the record no later than 7 calendar days from the last date of service. In many cases it will be impossible to comply with standard, and in cases in which the signature cannot be obtained in this time frame, there is no remedy for the provider preventing the provider from the ability to bill for services that were appropriately rendered. For example, the client is hospitalized or leaves town without notice and doesn't return home for many weeks. There are many other examples providers can give in which it takes many weeks and longer to obtain a signature from a recipient.
proposed regulations for the EDCD waiver
Remove the regulation that requires that providers obtain a proffessional referance for a nurse aide applicant that has only worked for 1 employer. Providers have found that many employers are unresponsive to reference requests. The requirement will eliminat a pecentage of potentially qualified workers because of the inability to get a response from a former employer. Given the shortage of nurse aides this would further limit the pool of potential workers needed to cover cases. We ask that personal references continue to be allowed.
Remove the requirement that nurse aides "physically attend" 12 hours of in-service education anually.Providers should be allowed to continue to utilize printed material and other mediums. It is effective and sufficient to require RN supervisors to provide instruction during home visits, when nurse aide deficiencies in knowledge are identified that are recipient specific.
Remove the requirement that signatures times and dates be placed on the record no later than 7 calendar days from the last date of service. In many cases it will be impossible to comply with standard, and in cases in which the signature cannot be obtained in this time frame, ther is no remedy for the provider, preventing the provider from the abillity to bill for sevices that were appropriately rendered. For example, the client is hospitalized or leaves town without notice and does not return home for many weeks. There are many other examples providers can give in which it takes many weeks and longer to obtain a signature from a recipient.
Remove the requirement stating that personal care aides attend 12 hours of inservices a year. Personal care aides complete monthly inservices provided by office staff and are then tested on their comprehension of this specific material. I strongly feel that the material provided prepares each aide for situations encountered on a daily basis. If caregivers are required to physically attend 12 hours of inservices yearly, they will not be able to meet the specified guidelines due to family obligations and other job schedules. Most personal care aides work at least two jobs and are single parents. To require personal care aides to complete 12 physical hours of inservices would be very unreasonable and unobtainable.
The RN supervisory visit should not be extended to 90 day visits. The majority of clients serviced require 30 or 60 day visits due to their condition. By requiring 90 day visits, hospitalizations will increase. Allowing a 30 or 60 day visit decreases hospitalizations because the clients care is being closely monitored by the RN and she can quickly catch a minor infection. I feel that 90 visits would greatly impact the health and well-being of clients.
Remove proposed regulation the requires providers to obtain professional reference for nurse aide applicants who have only worked for one employer. This requirement will limit the amount of potential qualified workers due to the inability to get responces from former employers. Personal references should continue to be allowed to gain more potential for qualified aides.
RNs with one year of experience are qualified to manage personal care to clients. In addition to their one years worth of experience they have their schooling and training from the agency who hired them to fulfill requirements set forth.
Requirement for the aides to attend 12 hours of yealry inservice training. Monthly hand outs and other mediums should continue to be sufficient enough.
Remove the requirements that states signatures, times, and dates be placed on the record no later than seven days from the last date of service. Examples of why this requirement is hard to comply with: Hospitalization, Car accidents, hazardious weather, client goes out of town, emergencies, etc. There are so many reasons for agencies not to be able to comply with the seven day requirement.
Remove the proposed regulation that requires that providers obtain a professional reference for a nurse aide applicant who has only worked for 1 employer. Providers have found that many employers are unresponsive to reference requests. The requirement will eliminate a percentage of potentially qualified workers because of the inability to get a response from a former employer. Given the shortage of nurse aides this would further limit the pool of potential workers needed to cover cases. We ask that personal references continue to be allowed.
Remove the requirement that nurse aides "physically attend" 12 hours of in-service education anually.Providers should be allowed to continue to utilize printed material and other mediums. It is effective and sufficient to require RN supervisors provide instruction in the home during home visits when nurse aide deficiencies in knowledge are identified that are recipient specific.
Remove the requirement that signatures times and dates be placed on the record no later than 7 calendar days from the last date of service. In many cases it will be impossible to comply with standard, and in cases in which the signature cannot be obtained in this time frame, there is no remedy for the provider preventing the provider from the ability to bill for services that were appropriately rendered. For example, the client is hospitalized or leaves town without notice and doesn't return home for many weeks. There are many other examples providers can give in which it takes many weeks and longer to obtain a signature from a recipient.
Remove proposed regulation the requires providers to obtain professional reference for nurse aide applicants who have only worked for one employer. This requirement will limit the amount of potential qualified workers due to the inability to get responses from former employers. Personal references should continue to be allowed to gain more potential for qualified aides.
Requirement for the aides to attend 12 hours of yearly in-service training. Monthly hand outs and other mediums should continue to be sufficient enough.
Remove the proposed regulation that requires that providers obtain a professional reference for a nurse aide applicant who has only worked for 1 employer. Providers have found that many employers are unresponsive to reference requests. The requirement will eliminate a percentage of potentially qualified workers because of the inability to get a response from a former employer. Given the shortage of nurse aides this would further limit the pool of potential workers needed to cover cases. We ask that personal references continue to be allowed.
Remove the requirement that nurse aides "physically attend" 12 hours of in-service education anually.Providers should be allowed to continue to utilize printed material and other mediums. It is effective and sufficient to require RN supervisors provide instruction in the home during home visits when nurse aide deficiencies in knowledge are identified that are recipient specific.
I feel that 1 year of experience for an RN is sufficient. I work closely with RN's in the Medicaid system and feel that asking for 2 years clinical experience is excessive. I feel that the supervisory visits, signing off on timesheets, and submissions to Kepro can be done with 1 year of experience.
I also feel that asking field employees to PHYSICALLY attend inservices is ridiculous. Committing to 12 extra trips to inservice sites is excessive. I feel like the current paper inservices are more valuable than people think. I have had first hand experience with these and feel that our nurse aides are getting the extra education that they need and it is sufficient.
I strongly disagree with the proposed change requiring personal care aides to physically attend a minimum of 12 hours of agency provided training. This proposed change would place an undue hardship on agencies who would be forced to pay employees for training with no hopes of being reimbursed by DMAS. The current method of training is adequate.
I agree with the proposed change of reducing the number of years of experience required for RNs from two to one.
I disagree with the requirement that providers shall require the supervising RN/LPN be available by phone at all times to the waiver individual. Again, this would create an additional expense for providers that would not be reimbursed by DMAS and create an undue hardship on agencies providing care. Additionally I feel that emergency calls should always be handled by 911 and that any non-life threatening issue can be handheld on the next business day.
Thank you for your review of my comments.
Please remove the proposed regulation that requires that nurse aides to physicall attend annually a minimum of 12 hours of agency training. These aides are already struggling financially to meet financial obligations. Requiring them to physically attend training comprimises their ability to pay for gas, or if its outside of working hours possibly pay for child care.
In addition, the inservices we provide is very informative, it motivates them to read regulary and learn about the field their in and situations the inservices provide.
Please remove the proposed regulation that requires that providers obtain a professional reference for a nurse aide applicant who has only worked for 1 employer. This requirement will comprimise the percentage of potentially qualified workers. It will discouraged them because of the inability to get a response from a previous employer. There is already a shortage of nurse aides. Placing this strain on them, will put a limitation on aides we have to cover the care of clients/patients.
I am asking that personal references continue to be allowed.
900: PERS definition--remove the clause about supervision. If someone needs supervision they often can't use PERC system.
920:C10--Change to a maximum of 5 hrs/day of pc for individuals in ALF. Rarely does someone living in the community need 5 hrs/day of ADLs. Why would they in AL?
925:B1b--change POC to plan to reflect current practice.C1--remove transportation. this is done by logisticareD.2.b. What about services in other school years besides postsecondary school? .D.2.b.1. Move this and clarify that the 56 hr/wk limit applies to cd pc also. Needs to be moved because it puts the limit only when they are provided in school or work. E.4.a. change from CY to FY. F.4. add "or attendant". H.4.a change from CY to FY. 1.c.1.remove clause about supervision. J.b. Add NF. K.3.f. add that the assessment can't be done by the provider, is current practice.
935:G.2. Add ongoing supervisory visit requirements for episodic respite. This requires only 1 visit ever. Add in addition to the one required, a supervisory visit after 240 hours have been used.G.4.e.3. change non home and community based records to "other" records J.a A year is way too long for an individual to wait for AT to be delivered. Change to 30 days.
Finding personal care aides in rural Virginia is a challenge - low pay rates and travel time and gas money make this field unatrractive. Requiring 12 hrs of formal training is too stringent and may be a detterent. PCAs can learn via printed matter, videos, on the job.