Page 6:  “Optima Health Community Care – Public Partnerships, LLC”.  Optima uses CDCN not PPL

Page 9:  F/EA is responsible for: “Provide quarterly reports to the EOR showing services used and services remaining”.  Also stated on page 12:  “The individual reviews the Quarterly Services Report provided by the F/EA. This is a report that provides information to the individual on the number of hours of service used, patient pay withheld, and how much each employee has been paid. This report will be sent to the EOR quarterly. Any errors noted should be immediately reported to the SF or F/EA.”  Is this new?  I have not received these type of reports

Page 11:  “The EOR must train the attendants and provide feedback as appropriate on timesheets. Every two weeks, timesheets will be due to the F/EA. The EOR and the attendant will determine the best system to enter and approve timesheets.”  With EVV & IVR there are no longer timesheets.  This statement is outdated and needs to be changed to reflect how EVV & IVR work

Page 11:  “The EOR must enroll with the F/EA before services can begin. The EOR must fully complete and return all forms found in the Employer of Record Enrollment Packet. The EOR must mail or email the original completed packet to the F/EA who makes sure all employment rules are followed for payroll. When the packet has been successfully processed by the F/EA, the EOR is ready to hire an attendant.”  The information contained in the enrollment packet should never be transmitted via unsecured method as it contains sensitive and private information subject to data theft.  Both the EOR manual and the process used by CDCN should be modified to prohibit transmission of this data in any form that is not secure.

Page 15:  “Documentation: The EOR should maintain a record that includes the service plan, timesheets, attendant application(s), documentation of TB (Tuberculosis) testing, if required, and any other information relevant to being an EOR of CD services.”  How is the EOR supposed to maintain timesheet documentation?  There are no options available to the EOR to maintain documentation.  There is nothing to print from the portal, EVV or IVR.  CDCN owns these tools and maintains that documentation.  Need to clarify what the expectation is here and if the EOR is expected to maintain timesheets, then the EOR needs the ability to print that documentation in a form that DMAS will accept. 

Timesheet section starting on page 16:  Needs revamped to remove all references to paper timesheets and be updated to reflect EVV/IVR, no longer allowed to use portal etc

Page 26:  “Timesheet Process: When completing timesheets, be aware of the number of hours that have been authorized and do not approve attendant timesheets for more hours than have been authorized. Doing so will delay processing of the timesheet.”  With EVV & IVR, EOR has no easy way to monitor total hours for a day using Celltrak given that attendants log in/out 4 or more times per day without logging out to check totals.  The app functionality needs to be substantially improved if you are expecting the EOR to be required to monitor this data.  Currently it is a nightmare and leads to all kinds of false overruns. 

Page 26:  Timesheet Process:  “When employing multiple attendants, be sure that the timesheet attendant hours do not overlap. The F/EA cannot pay for overlapping hours.”  CDCNs EVV system collects time to the second, yet it cannot recognize that one attendant’s shift ending at 11:43:21 does not conflict with attendant 2’s shift starting at 11:43:53.  CDCN needs to fix this problem since the shifts do not overlap.  The EOR has no recourse to fix this problem and pay is being cut incorrectly when this occurs.

The manual does not address anything related to EVV/IVR and that needs to be clearly addressed.  Using the Celltrak app is a nightmare and the EOR manual need to go into great detail about how the system works and what the EOR can to do work around all of its limitations, restrictions, etc. 

Finally, please remove the requirement that live-in attendants be subject to EVV.  The requirements for a live-in companion just do not make sense and add a bureaucratic layer that is not needed.

Thank you