Many of the proposed changes to be made will inevitably fall to the responsibility of the Employer of Record (EOR), who is also the person that typically interacts the most with the current contracted Fiscal Agent, Consumer Direct Care Network (CDCN). 

The EOR role is the only role in this entire process that is unpaid and is not counted towards the services received by the waiver receipient. By the nature of our relationships to many of the recipients, we also often provide attendent services that are not factored into the plan of care or counted towards the hours needed for the person to remain safe in their home/community.  In addition to that untracked data, EORs have a moral and legal obligation to fulfill our EOR obligations we must take time away from paid jobs to complete required tasks, which often includes checking and balancing what tasks are assigned to the service facilitator, CSB manager, and the fiscal agent (CDCN). 

These proposed changes will require more efforts from the EOR to manage the transition and troubleshoot any issues that will undoubtly arise from an effort of this magnitude happening simultaneously. 

• Expecting newly onboarded support brokers to navigate not only the standard role of the prior service facilitator, but also the volume of required exception waivers for personal care assistance at the same time unreasonably increases the risk to the delivery of waiver services, which is directly connected to the health and safety of the lives of waiver recipients. 

In engaging with CDCN I find it hard to fathom that they will be able to execute the support broker role without significant service delivery impact as I have personally had to repeatedly navigate their inability to consistently fulfill their contracted fiscal agent duties. In addition to my personal experiences, I have read countless complaint from consumers and their support networks who have reported these issues to DMAS, but rather than those being adequately documented and addressed with the vendor they are being given additional scope, responsibilities and likely funding to have an even broader impact on the delivery of waiver services.

Just recently in attempting to onboard a new attendent it took a series of back and forth emails followed by a call to be able to receive a secure email from CDCN in order to attach the manually completed attendent packet in a secure manner. While there is an option to use Docusign that was not an option in this instances and it was only due to my refusal to send PII through unsecured email channels that it did not happen that way, as that was what multiple personnel suggested including a supervisor. This was extremely concerning to me, as that means that this is likely what is happening regularly, which leaves DMAS liable to the legal consequences of PII violations.

Furthermore, it goes without saying that their implementation of EVV was and continues to demonstrate unsatisfactory performance.

• Attendents continue to receive emails with threatening tones for alleged "non-compliance" even when they have done anything to trigger the message or when there is a legitimate reason to be non-compliant e.g. system-wide cellphone outages.
  • When EORs reach out about these issues we receive the same canned response without any effort to look into the specific matter and/or track the data on the inaccurate triggers in order to develop a mitigation plan. 
• The mobile device interface is not user friendly and limits the available data visible to the user, which makes using the website DirectMyCare necessary for attendents to track time, enter in sick leave, etc...