DMAS reportedly told Virginia state delegates it would take them until Jan. 2021 to identify live in providers.   DMAS knows that the fiscal agents ACCE$$, CDCN, PPL all already have live in providers identified.  That that group of attendants are exempt from paying federal taxes and can work over 40 hours a week.   

"DMAS' EVV system regulatory requirements comport with § 12006(a)(5) and do not exceed the minimum requirements contained in federal law" is written on the Proposed Regulation Agency Background Document...  requiring live in providers to do EVV is exceeding minimum requirements of federal law. 

on the Economic Impact Analysis it is written "Projected Impact on Employment
The proposed amendments are unlikely to affect total employment. In the short run, more
jobs may have been created by the demand for new software solutions to meet the EVV
requirements. This regulation is unlikely to affect the ongoing shortage of home health care and personal care workers"  this is also incorrect... hundreds of consumer directed clients cannot now hire attendants over EVV; most agency directed attendant care providers are going out of business.  MOST of the low paid care providers are people with low education but kind hearts.  Many don't use a smart phone or have limited services and EVV costs them money they don't have.  They are far better off to take a better paying job at a fast food restaurant.   EVV has made it impossible to hire attendants.  

The other large group of providers are live in family and friends.  Many of these people gave up higher paying jobs to help their loved one.  I know a physician assistant who quit working when her daughter aged out of school.  She had been make $80,000 a year.  I know a teacher who was making $64,000 a year who also decided to prevent her child the harm he would experience in a government placement to stay home and live off the $19,000 the CDPA job would offer.  

The live in providers care for the individuals 24/7 and are usually only reimbursed 8 hours a day for the care.  DMAS is asking them to make up shifts to enter time..  when in fact they are on duty all day every day.  this is a major hinderance.