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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1/20/20  8:50 am
Commenter: Charlie Davis

EVV is putting me in a nursing home

My family does not have to care for me (they have other means), but they do because they don't want me to go to a nursing home.  They had bad experiences with nursing homes with other people in my family.  Now, with evv, it is like the straw that broke the camel's back.  Late at night I hear them saying they are going to go ahead and let me go to a home.  One says they can't do it; the other says they are going to have to. They say it's not worth throwing their lives away along with mine.  Can you imagine how I feel?  The invasion into our lives with evv and privacy and the obligation and burden to click something at least twice a day has certainly gotten to them and it is killing me.  They talk about how they deserve privacy and a sanctuary in their own home and how evv is taking that away with having to say where everyone is at least twice a day.  They say their home is being turned into an office.  They say how the pay is low and not worth even being reimbursed.  They talk about how they need lives too.  They say they are giving up their lives when they let evv in the house.  They talk all the time on the phone and in person dealing with social security, medicaid, the people that visit each month, the people that handle pay, my trust, my doctors, my lawyers, my evil side of the family, and plenty more just for me.  They say they are dealing with enough agencies and bad family that they cannot handle the many times they have had to deal with the pay company over this evv.  They say they can't remember in their own homes when trying to care for me to clock in and out at certain times especially when I need their care over things I struggle with to stay alive; they say it just adds to an already difficult life.   Stop evv please. I want to live with them and have a normal life not a nursing home life!

CommentID: 78859

1/20/20  10:44 am
Commenter: Barb Wilson

Why burden the overburdened??

I am a live-in caregiver and when there are emergencies such as toileting accidents or worse in the middle of the night, my job is to care for the person not the clock FIRST.  THE PERSON comes FIRST.  Getting this person to their specialist appointments on time comes first!  Not the clock.  All appointments are all out of town as we live rural.  It is a very daunting task trying to schedule around the EVV which does have many glitches.  Why is it that the state, insurance, and evv glitches are overlooked and acceptable, but the provider gets the blame and is threatened with not being paid for work that has been done? ! There is a caregiver crisis: don't burden the overburdened with evv, for heaven's sake!

CommentID: 78862

1/20/20  2:30 pm
Commenter: Matt Taylor

Poor and disabled do not deserve less in basic privacy and protections

There are plenty of privacy concerns raised with EVV and there are many known inaccuracies that could hold the user responsible.  Those who cannot afford more do not deserve less in basic privacy and protections. Just because someone happens to be lower-income, disabled, and on the waiver doesn't mean they should be the ones losing their rights to privacy by being forced to use EVV/GPS to receive care and being used as guinea pigs for the flawed software. 

CommentID: 78867

1/20/20  5:42 pm
Commenter: Pat Cook

Stop GPS tracking and wasting our time with time consuming clock ins

The apps have so many steps.  It is time consuming.  If there is a problem with app. and it takes 20 minutes or so to fix it, will people be compensated for their time?  There needs to be a better format and stop the GPS tracking. It is an invasion of privacy in the home. 

CommentID: 78873

1/20/20  5:55 pm
Commenter: Carol R.

Exempt live-ins

Wonder why all family members who are caring for a person who has developmental disabilities and who lives in ANY location of their choice are not exempt from EVV?  CMS considers them exempt.  Shouldn't the person who has DD have the right to live where they wish while having the caregivers they desire, without having their privacy infringed upon?

CommentID: 78874

1/20/20  10:19 pm
Commenter: S. Coleman

Deception: GPS tracking and "location twice a day"

GPS tracking someone's life with EVV in their home and in their community is wrong.  It is so wrong that states have been advised to refer to the GPS tracking being done as "location only twice a day".  The states never refer to the GPS tracking they are doing as "GPS tracking" which is very deceptive.  The EVV app. people are being forced to use does not work on a device that does not have GPS and GPS must be turned on when clocking in/out.  So, let's face it, everyone is being GPS tracked.  Many folks have to clock in/out more than twice a day, so that statement, "location only twice a day" is also not true.  Stop tracking the lives of law abiding citizens and calling it something else!

CommentID: 78878

1/21/20  10:16 am
Commenter: Maria

The EVV app. is always a problem

Every day it is some new problem.  lately, the location is turned on, but the app. tells me that it is not turned on. 

CommentID: 78879

1/21/20  3:04 pm
Commenter: A. Green, Patient Advocate

Many Participants are EOR's and pay for their own care and they are having EVV forced upon them??

Why are consumers/participants having no say in EVV and it is being forced upon them? They hold the role of EOR and they pay for a portion of their care out of their own funds through patient payments!  They deserve the right to have a voice when it comes to EVV! 

CommentID: 78881

1/21/20  3:41 pm
Commenter: J. Martinez

The app. errors are going to make me look like I am committing fraud

My attendant submitted the usual shift one day.  Right after they submitted, I approved.  The next day, there were extra hours added to her regular time that no one had submitted and the hours were even approved.  Now I am afraid I will be accused of fraud.

CommentID: 78882

1/21/20  4:23 pm
Commenter: Shellette Williams

Let’s fix home health, not add to it’s problems

I have been on the Medicaid Tech Waiver for 12 years since 2007. I am a 46 year old ventilator dependent mother of 4 with muscular dystrophy. I have seen a slow decline in the quality of nurses that have cared for me. I fear that this new EVV system will continue to scare the good nurses away. My agency seems to be the only agency in my area that is even using this system. That is unfair because once the word gets out, that agency will lose some of the nurses they have and they will have a hard time recruiting new nurses. 


I know they’re are pros and cons to any new system and there also needs to be a learning curve and an outlet to submit recommendations for improvement. For one thing, the grace period for clocking in and out. What if the nurse is 15 minutes late, missing the 10 minutes grace period, she is unable to clock in. Then if that same nurse wants to stay 15 later to make up her time, she misses the 10 minutes grace period and she can’t clock out. This happens often because most nurses have more than one job and work for several agencies due to low wages and the lack of affordable health benefits.


Another problem is internet service problems. I don’t even live in a rural area and often my nurses tell me that they can’t clock in because the system is offline or it can’t connect to a network, so what are they supposed to do?


I understand the need to hold everyone accountable but there has to be a better way. It’s hard enough being disabled but having to worry about suitable caregivers adds to our stress and can lead to depression. The atmosphere of home health is already in dire straits and I fear that in a couple of years, there will be very few nurses who will want to do home health, so let’s work to make it better not worse.



S. Williams

CCC Plus/ Tech Waiver Recipient 

N. Chesterfield, VA

CommentID: 78883

1/21/20  9:13 pm
Commenter: Concerned Citizen

The Federal Government has already exempted Live-Ins from EVV

The Federal government has already exempted live-ins.  Why has the state not exempted live ins?  There really is no excuse for allowing such invasive technology to enter a live-in's life....NOT VISITS....LIVES.  Exempt Live-ins now; do not delay!

CommentID: 78884

1/21/20  10:04 pm
Commenter: Trini Johnson

My work disappeared on the evv app

Four days of work that I approved for my worker has disappeared on the timesheet in the app.  I had to go back in and answer all the questions and redo all the hours.  This is pure insanity; evv is not a simple clock in and out procedure.

CommentID: 78886

1/22/20  12:06 am
Commenter: T. Moore

Exempt Live-Ins from EVV

First of all I want to say how grateful we are for this program. We are able to care for our mother in the comfort of her own home where she has lived for 51 yrs. We are able to do so on our own with no worries of having to deal with aides, nurses or a facility that is too busy to give her the care she needs and deserves.

It is very disheartening to hear some if the comments that people have posted. Fear of losing benefits or fear of being sent to a nursing home because evv has posed a hardship on their lives.

I understand the need for evv to ensure employees are coming and going as they should...ensuring they are not falsifying records. But it becomes a little more difficult when u  are a live in.

A livein does not awake to being able to prepare themselves to go to work. We dont walk into the consumers home at a set time and clocking at that time. And when we have worked our hours for the day, clock on our way out the door. We awake to work. Most of the time our work begins as soon as our feet hit the floor and doesn't stop when we clock out. We are helping our loved ones live in the time frame they want to live in because they know we can and in doing so how can we fit into a timeclock punching schedule.  That's really just not how it works when u reside in the same place of the person u care for.

I hope our comments help u to understand our struggles.



CommentID: 78887

1/22/20  8:53 pm
Commenter: Dick Jenkins

live-ins don't visit. exempt live ins from evv (electronic VISIT verification)

it is impossible to visit your own home. 

CommentID: 78893

1/22/20  9:58 pm
Commenter: Liz Rodriguez

EVV GPS tracking says I am not where I am supposed to be, but I am where I am supposed to be.

I am being framed.  Says I am 98 miles from my client's home AND I am in the home!  It is torture to use EVV.

CommentID: 78895

1/23/20  6:21 am
Commenter: Maria Galifianakis-Croke

Double & Triple Time Spent Hacking at EVV issues

Thank you for the opportunity to comment. I have a large, nonspeaking, non-compliant combative child on a special diet and, with an attendant's help, have to eek out time for me to go to bathroom or shower, for me to eat, or tend to the rest of the my family. These days I am eeking out those moment in order to tend to glitches, problems, mysterious issues with the EVV. My attendants have not been paid in weeks, we have taken out a personal loan to pay them out of pocket. THIS IS AWFUL, TORTURE TO THOSE OF US WHO RELY ON ATTENDANT CARE.

CommentID: 78898

1/23/20  7:17 am
Commenter: Erin McPherson

Disabled people & their caregivers do not deserve this invasion of privacy

My entire family, unfortunately, is disabled: my children, my husband, and myself. My children have attendants who help them daily with a variety of tasks. The EVV app is difficult to use, tracks their location, makes approval of hours more difficult, uses up a lot of memory on their phones, and just doesn’t work. In addition, it is absolutely wrong to have my children’s as well as their attendants’ privacy invaded like this. I do not think this is or was ever a good idea.

CommentID: 78899

1/23/20  9:57 am
Commenter: Polly Rivera

Why is DMAS telling delegates they need a YEAR to indentify live ins? DMAS has the lists already.

Live ins fill out special forms with the DMAS appointed FA (fiscal agents) when they start working.  The FA's work under and for DMAS.  LIve ins have the same address on file with the FA as the consumer/participant/client.  They are often family and often have the same last names (participant and caregiver) on file with the FA.  These FA's work for DMAS.  All DMAS has to do is request the lists from the FA's that work under and for them.  The live-in lists are easily, and readily available. 

CommentID: 78904

1/23/20  10:20 am
Commenter: Chuck Cox

My Child's daily emergencies were not meant for a app with a complicated questionnaire sign in!

Imagine the daily life of someone who has sacrificed to care for their child, so their child is not in a nursing home.  That is me with 24 hours a day availability.  If YOUR son or daughter was in a medical crisis not breathing, would you want to have to take time to answer several questions on an app., then punch a clock before saving their life?  Ask yourselves that and then thank God you do not live in my grateful not hateful for once! 

CommentID: 78905

1/23/20  10:28 am
Commenter: ANON

Don't put my son's services in jeopardy over forcing live ins to clock in and out constantly

I should not have to clock in and out,in my own home, to care for my delicate and infirm son.  His services should not be held ransom in order to force this on me as well.

CommentID: 78906

1/23/20  11:22 am
Commenter: Tommy Johnson

"No more turning away from the weak and the weary" - listen to the disabled crying out against EVV

When you do not listen to hundreds of the disabled crying out for EVV for live-ins to be struck down, you are turning away.  Pink Floyd said it best:

On the turning away, from the pale and downtrodden and the words they say which we won't understand.  Don't accept that what's happening is just a case of others' suffering or you'll find that your're joining in the the turning away.  It's a sin that somehow, light is changing to shadow and casting it's shroud over all we have known.  Unaware how the ranks have grown.  Driven on by a heard of stone.  We could find that we're all alone in the dream of the proud.  On the wings of the night as the daytime is stirring, where the SPEECHLESS unite in a silent accord.  Using words you will find are strange and mesmerized as they light the flame.  Feel the new wind of change on the wings of the night.  NO MORE TURNING AWAY FROM THE WEAK AND THE WEARY NO MORE TURNING AWAY FROM THE COLDNESS INSIDE.  Just a world that we all must share.  It's not enough just to stand and stare.  Is it only a dream that there'll be no more turning away??

CommentID: 78908

1/23/20  11:56 am
Commenter: you need to know this

Federal Mandate says not to cause a burden to caregivers - EVV causes a burden to live ins

One does not have to go far or listen too hard to understand that EVV, especially for live-ins, is a burden and a failure.  Federal mandate requires that EVV not be a burden.  The system in place before was working.  Live in caregivers were allowed to submit their hours when they had a minute available.  A minute available is rare for a live-in especially when the care can go from monotony to emergency in the blink of an eye!  They do not have time to answer a questions every single time they sign on and clock in/out on a troublesome app. with an arbitrary set of hours (live-ins work much more than hours assigned).

CommentID: 78909

1/23/20  1:29 pm
Commenter: Ellie Nguyen, advocate

Try asking a policeman or fireman on the job 24 hours a day to punch the clock at arbitrary times

Wait a minute, policemen and firemen are salaried, well paid, get overtime, get vacations, and get breaks!  Well, let's just say for hypothetical sake they were working 24 hours a day and we asked them to punch a clock at certain times.  Due to their unscheduled, impromptu, erratic emergencies, it would be impossible.  Welcome to the world of a family caregiver just trying to survive and you want them to do what?  Please rethink this and let's move forward.  Thank you for your time!

CommentID: 78911

1/23/20  8:20 pm
Commenter: Autism Mother

EVV / Severe aggression

OUR son is severe disable. Autistic and Non verbal, he can be severe aggressive. He loves iPhones. The attendant can not use iPhone in front of him, otherwise he will have behaviors. EVVV is a big obstacle to find new attendants, to track the specific time of services in front of him, specially if the app is not working.

I'm trying to understand why somebody would like to work for my son for 12.00, without any benefits and get bitten for using an iPhone? why anyone would work for a disable individual?


CommentID: 78914

1/24/20  12:38 am
Commenter: Van Lee

Neglect & Abuse of the family caregiver during a nationwide caregiver crisis - EVV adds to the abuse

Family caregivers receive abuse and neglect every day.  They are neglected in that the majority receive no benefits (NONE).  Many are spit on, sh** on, or hit on repeatedly by those receiving their care.  It is a thankless job.  Some days, there is not a song in their hearts, but they keep singing anyway, because they know caring matters most in life.

EVV adds mental abuse to the abuse/neglect family caregivers already receive.  EVV tells caregivers they are worthless, and deserve to be tracked like criminals.  The national caregiver crisis started before EVV.  EVV will end up making this crisis worse by turning a thankless job into a loathsome job.

CommentID: 78915

1/24/20  8:30 am
Commenter: Hanover Community Services

EVV Issues

As a Program Coordinator for Supports Coordination I have heard nothing but difficulties with staffing and care since the inception of EVV.  We have several areas of the county that does not have internet and this creates difficulty for staff to call in.  Also, some families have had their care staff resign because they only can afford a trak phone and this is incompatible to the system.  We have heard that this new system is creating  much more burdens on the care of their loved one.  Please reconsider having this requirement. 

CommentID: 78916

1/24/20  9:10 am
Commenter: Dede

please remove ebv

Plesef remove ebv.  It is hard to use and I can't find peopel to help me as much anymore. some one was living with me until one year before i was given a ebv device.

CommentID: 78917

1/24/20  11:27 am
Commenter: Nancy Hemenway

The EVV Threat to Consumers with Disabilities

EVV violates privacy, sets up the consumer, the (Medicaid) recipient, and the agency for problems and hacking of cell phone networks housing private patient information. And EVV, I suspect is absolutely a HIPAA violation.

The 21st Century Cures Act does NOT define "location". The VA legislature took it upon themselves to not only add a GPS tracking mandate to EVV but also biometrics. The view of those of us who protect our disabled family members and their privacy is that this is outrageous. The mandate is counterproductive and counterintuitive particularly for caregivers who provide care within the family structure. 

Let's look at the implemented mechanism (Public Partnerships) employs and mandates attendants use. The Time4Care app does NOT work - for IOS devices (a large if not dominant part of the cell phone market). 

I have contacted Public Partnerships (PP) more than 60 times over the last 3 months (by email and phone) because of their non-working app. I had a lengthy discussion with their technical help desk. Please also note that I contacted PP many times when they NEVER alerted me to the fact they even had a help desk. There is no help desk number on their website and it appears they don't often explain to the consumer that there is a help desk. 

Time and time again I have asked for a superior to contact me and intervene.  At one point I was told my concerns had been escalated although no one followed up with me. Another time I did speak with a supervisor who promised a follow up so I could send Public Partnerships screenshots of what was happening to our IOS devices. She never sent me her contact information.

Right after the discovery of a technical support help line (December 2, 2019) I spoke with  supervisor  Maria J – who me with the tech help line number 833-204-904

The person I spoke to was “Rob” in a center in AZ.  I asked many questions. "Rob" told me the app corrupts data, he also said, “...It wasn’t developed on a robust platform”  like apps the government uses to secure data.  He might as well have followed his thought that our consumers with disabilities are really just second class citizenry that doesn't really warrant the type of care and protections that securing privacy information warrants from the apps used by the government or in the healthcare industry that are secure. 

Time4care was NOT developed to be EVV compliant – it was developed (according to their tech people) for time entry only and the EVV mandate an after-thought "Rob from Public Partnerships in their AZ center" also told me the app (Time4Care) it was NOT developed to handle IOS systems. 

iPhone which is the #1 smartphone in U.S. market share. Of these, approximately 40 % of users, use an iPhone in the US

Public Partnerships help desk representative "Rob from the AZ center)" told me that they are aware of the problems but that THERE ARE NO PLANS TO FIX THESE ISSUES.
My attendants have to edit times DAILY because the APP (Time4Care) does NOT keep accurate times. Yet, each time and with EACH EDIT  to correct the times and manually fix the times (the app doesn’t track) there is a message threatening services for my neurologically disabled daughter. 

Public Partnership "Rob in the AZ Center" on or around December 2, 2019 let me know there are solutions to their ill-conceived application. He provided two in fact – 1.) we can uninstall and reinstall the app daily or weekly (however that has never worked for us) OR we can use a maintenance third party app to clean the phone files. We can just download some unknown app to clear what "Rob from the AZ Center" referred to as "corrupted data".  Rob then said he couldn’t suggest such an app because unless it was approved by the state, we just have to Google it and take our chances with further IOS problems.

This is absurd and ridiculous by any measure of common sense but beyond this, the mindset is of individuals with disabilities as 2nd Class Citizens who don't warrant protection and privacy

Further Thoughts on EVV and the Effect on the Community

EVV threatens decades of the work to create a more independent type of living situation for our daughter and for us – her family. EVV has no place in Personal Care Services or Consumer-Directed Services, or in waiver programs that offer consumer directed-like options. While some states refer to their programs by differing names, consumer directed programs provide our daughter with: choice of service provider; location of service (home or community); scheduling responsibilities; and consumer control. For our daughter this is a life-saving situation keeping her toxic stressors low and allowing us (her family who loves her) a situation where we can keep her safely in her home.


EVV in all forms erodes our rights to provide appropriate care by eliminating the ability for us as her guardians to direct care at her own volition and support her plethora of needs. Her care isn’t just a “preference” it is statutory to her well-being.

EVV does not empower her as a person with a disability, but instead holds us back. When we adopted her she was stripped of her rights, dignity, privacy, and independence. We changed all that for her BUT EVV once again threatens her rights.


The federal EVV mandate, was not created because of the need to eliminate fraud in Medicaid personal care services. EVV is a massive financial giveaway to technology vendors of EVV systems. Our first priority is to care for our daughter, this means if I am up with her in the middle of the night, or if she has a seizure, or an aggressive behavioral trauma response, we do not have the time or inclination to grab a cell phone, log in, to clock in. This is ridiculous for most but more so when the caregivers ALL live with the recipient of services at home.


Virginia also violates our daughter’s dignity and human rights through the use of Global Positioning Systems (GPS) and biometrics. This type of monitoring is a direct and excessive violation of the privacy and potential safety of individuals living with disabilities and more than likely a HIPAA violation.


Given the growing frequency and size of private data breaches, consumers are or will be required to tolerate additional intrusions and burdens under EVV, just to receive the life-sustaining care on which we rely to allow her to live independently with us and avoid institutionalization.  Our daughter is an immigrant who became an American Citizen when we touched down in LAX from China in 2001. Yet she is often treated like a second-class citizen. It took a year, $1100 and the help of the Honorable Tim Kaine’s office and intervention for us to get her certificate of citizenship which should have been presented automatically like all international adoptees that enter on the correct IR3 Visa. We feel threatened by the current immigrant climate and this EVV action is just one more hurdle put in our path.


As an American citizen Bekah is guaranteed Constitutional protection from these types of privacy intrusions, and as her mother and legal guardian I demand that she and other Americans with disabilities have equal protection under the law. I know Dr. Northam as pediatric neurosurgeon, cares about those who due to neurological damage, cannot fair for themselves.

GPS and biometrics have a chilling effect on the independent providers and the entire personal care assistant network. It is almost impossible for employers of record (EOR) who are often family members to find adequate attendants. EVV further shrinks the chronically inadequate pool of available employees.


Attendants work for minimum wage, often under stressful behavioral conditions. Attendants are reluctant to be geo-located during their work day, to be biometrically identified, or to take a job requiring technology skills without increased compensation. Quality care is what is at risk here.  Some employees are cautioning consumers they will leave once subjected to EVV.


Potential workers are going elsewhere when they learn that GPS or biometrics are required. Individuals with disabilities across the country are facing increased provider shortages because states are not prohibited from utilizing GPS and biometric features under EVV.


People with disabilities have a right to transparency and access to any private data collected. The EVV industry is not forthcoming about the type of data it collects and stores. Data compromise and loss prevention plans must include immediate notification of any breaches to consumers and providers. Threats to identity protection and digital privacy should be given the highest accountability priority.


People with disabilities have the right to control their lives.

If individuals are to make informed decisions, it’s imperative that states create and implement comprehensive outreach and education to consumers and providers about EVV choice options, such as web portals.

CommentID: 78919

1/24/20  11:46 am
Commenter: Topper Kim

What Hemenway said about EVV below in comments is true

Thank you.

CommentID: 78920

1/24/20  11:54 am
Commenter: Lucy Patel, concerned family member

EVV needs one more "V" for vampire - time vampire

writing this note now is a time vampire when family caregivers have very little and very unpredictable free time as it is.  Between having to diplomatically handle all the issues/problems evv has caused with payroll to having us time in and time out over and over even when we live at the location and each and every time in & out, answer questions.  it is just a failure on a grand scale.  Thank you for your time (said the vampire)!

CommentID: 78921

1/24/20  12:04 pm
Commenter: Bach Hill

We know evv LOBBYISTS exist

EVV in all waiver families' homes is a big pay day for evv lobbyists and those being paid by EVV lobbyists. 

CommentID: 78922

1/24/20  4:00 pm
Commenter: Lon Walker

there is no place like home stop evv

don't take home away for many.  the only option if evv does not work is a nursing home.  stop evv.

CommentID: 78926

1/24/20  7:09 pm
Commenter: Stephen Grammer Disabilities Advocate

Stop EVV

People with disabilities, cannot hire caregivers because the pay is to low. EVV makes things more difficult to get attendants, because the landline and the App doesn't always work. As a result, disabled individuals will be forced to live in nursing homes violating our ADA rights to live in the least restrictive environment.  

CommentID: 78929

1/24/20  10:10 pm
Commenter: Betty Chang

Exempt Live-ins

Families don't deserve this.  Exempt live-ins.

CommentID: 78930

1/24/20  10:24 pm
Commenter: Lynne Brown

Virginia's end user stakeholders were never consulted when EVV was introduced

If all stakeholders had the opportunity to give input on EVV, money and time would have not been wasted.  The majority of the largest group of stakeholders, the end users, were blindsided when EVV was revealed to them in fall of 2019.  They were not given a voice when EVV was introduced. Now, EVV is chaotic at best and should have never been implemented. 

CommentID: 78931

1/25/20  7:19 am
Commenter: Kirk Ferrell

Live in father issues

I retired to handle our disabled son who is 21. He is 6 foot tall and 280 pounds. With mental and physical disabilities and aggression, it’s all we could do. I am with him almost every moment except when he is in a special school or a man from church takes him once a month on the weekends. There is no such thing as checking in and out for me except for those two situations. Please exempt live in’s. It’s hard enough. 

CommentID: 78932

1/25/20  9:16 am
Commenter: Bitsy Martin


exempt live-ins.  cms will not be charging or fining virginia for exempting live-ins. 

CommentID: 78933

1/25/20  1:20 pm
Commenter: T Burns

Exempt Consumer Directed Services from EVV
I am begging VA legislators and Governor to help fix this disaster we call EVV.
VA's needs to exempt Consumer Directed Waiver Services from having to use EVV.  Agency directed can continue to use it, but families and individuals using Consumer Directed Services should be exempt from this requirement.

The 21st Century Cures Act does NOT define "location" in its legislation. The VA legislature  added a GPS tracking mandate to EVV and also biometrics. No other citizen group in VA is required to be GPS tracked to receive services they have qualified and are eligible for. This treast individuals with disabilities as 2nd Class Citizens who don't warrant protection and privacy

The APPS that families and caregivers are required to use are full of glitches and many times do not work correctly.  My son's attendants have to edit times all of the time because the APP either does not keep accurate times, or just will not work. Each time there has to be a manual edit, there is a message threatening services for my adult son with autism.

EVV threatens decades of the work to create a more independent life for individuals with disabilities. EVV has no place in Personal Care Services or Consumer-Directed Services, or in waiver programs that offer consumer directed-like options. While some states refer to their programs by differing names, consumer directed programs provide our son with: choice of service provider; location of service (home or community); scheduling responsibilities; and consumer control

The Federal mandates in the 21st Century Cares act can be met by utilizing the system that was already in place (web portal and print time sheets) and added a space within each of those to indicate location of services.  No app, no gps, no biometrics are required. 

There is already oversight put into place for these services.  At least once a year my son has to be evaluated to determine he still qualifies for services and to see what his needs are.  A proposal for the number of allowed hours and types of care are sent to the state for approval.  After hours/services are approved, a case manager and a service facilitator both check in monthly on those hours and services.  In addition when someone submits a timesheet, I as the Employer of Record would approve those hours as well.  EVV just adds to this and is a burden to families and attendants. 

The federal EVV mandate, was not created because of the need to eliminate fraud in Medicaid personal care services. In fact studies show that most of the "fraud" issues come from agencies and not individuals getting paid $9.44 an hour prior to taxes.  Consumer Directed Services need to be exempt from this system.

CommentID: 78934

1/25/20  2:11 pm
Commenter: Kim Watts

Ifsp grant October 2019

The Ifsp website shut down October 1 after being turned on for application submissions. When I logged in 15 minutes after it opened the website was shut down . We were told those of us who did not get to submit an application would have an opportunity at a later date. We still have not been able to submit an application. But the people who got their applications submitted the day the website crashed have already received there $1,000 cards in the mail as of this past December 2019. This is so unfair. I have a saved application in and there has to be a better system. I am not alone many people are very upset. We still now have no information on when or how we will be able to get this $1,000 grant for my special needs son. I want a resolution in this.

CommentID: 78935

1/25/20  4:43 pm
Commenter: Diane Coyle

Stop EVV for Live In Providers

Please eliminate the EVV requirement for Consumer Directed Services, in particular for live-in providers.  We were not given an option so we started using the EVV app, CellTrak in Fall 2019.  It has been a nightmare.  Many days the app doesn't work.  When it does work, it is difficult and cumbersome to use.  The expectation that my son's live-in caregiver, his father, has to clock in and out multiple times per day to record "shifts" is ridiculous.  With Companion Care services he can only record a max of 8 hours per day (per DMAS Service Authorization).  Do you have any idea how difficult it is to get the app to record 8 hours exactly?  Impossible.  If he records 8 hours and 1 minute, he is in violation of the service authorization.  However, if he adjusts the time to 8 hours even using the portal, he is in violation of EVV and has to explain the "error" by choosing one of several drop down options which place blame on the caregiver.  There is no option to say that the app doesn't match the service authorization or that the app is difficult to use.  Also, when I fixed another "error", I received and email from CDCN telling me that if there are too many we run the risk of either losing services or requiring re-education.  I know how to record 8 hours/day -- had NO trouble when using the portal.  The app is the problem and makes us appear to be non-complaint.  AND, even better, before CDCN started rounding time, if the app recorded 8.01 or 8.03 hours/day, at the end of the 2 week period that sum exceeded 112 hours (regardless of how small an overage), then an entire shift was not paid.  In the last example, the sum was 112.32 hours (sum of minor overages for each day totalling 19 minutes, that is 1.9 minutes per day over) so CDCN did not pay the caregiver for a full 8 hour shift.  The system is not even smart enough to recognize minor overages.  But now, CDCN is rounding hours on the portal but not on the app -- so guess what?  More challenge in trying to figure out what hours have been recorded.  Recently, caregiver recorded 3 shifts; app showed 8 hours on the phone.  BUT, portal showed 8.25 because the portal rounded the hours in each individual shift causing an overrun in error.  There is no need for this insanity.  Let live-in providers go back to using the portal.  It used to take us a quick 5 minutes to enter a days time.  There was no fraud, there was no need to know where the service was provided, there were no bogus "errors".  EVV is causing problem that never existed and I can't imagine there is any benefit to it at all.  STOP EVV FOR LIVE-IN PROVIDERS!!!

CommentID: 78936

1/25/20  8:51 pm
Commenter: Missy Tran

Consumer Direct Services are the most affordable services for the state - EVV is eroding CD svcs

That's right.  The most affordable services for the state are consumer direct services.  EVV is turning the difficult job of consumer direct services into a repulsive job.  NO one will want to do the job, and everyone that is living with a disability will be right back in institutions.  Virginia, work on fixing this now, before there is no return.  Start by exempting live-ins, which is easily done, and don't stop until this horrible situation is remedied. 

CommentID: 78937

1/25/20  11:19 pm
Commenter: E. Warren

EVV for live in attendants takes away dignity

Caregiving has always been a field where the kindness of another is exploited by the offering no benefits for a very difficult job.  It is assumed, the caregiver won't speak up for better standards because they are nice, caring people.  EVV has added to that exploitation by taking away any dignity left in consumer directed services jobs for family caregivers.  How dignified is it to ask someone who is living in the same home as the person they care for to prove that several times a day with a GPS tracking device like a common criminal on house arrest?  As if mutual location is not already proven by the many public records available.  Family caregivers will eventually be forced to give up to preserve their privacy and dignity.  Possibly that is the intention of the state: to have the caregivers give up, thus forcing the disabled back into institutions. 

CommentID: 78938

1/26/20  6:46 am
Commenter: Lisa King

EVV is not "a life like yours" for families managing a disability

 Do you anguish over a clock constantly all day and night in your own home? Do you have to set alarms around your house to remind you to push a button at arbitrarily set times (because you live there and don't visit)? Are you GPS tracked in your own home and community by several agencies?  Do you often deal with payroll and tech support, that rarely answer, due to a faulty app necessary just to punch a clock?  If you punch a clock, do you have to answer several questions each time you do clock in/out?  Do you anguish over whether your family member will end up in an institution, because you couldn't live up to impossible standards, were framed due to app. issues, or couldn't accept being GPS tracked?  Do you have to buy (on $9 an hour with no benefits) an all new separate phone/device with GPS capability and paid service just to keep your personal phone or device from losing all privacy?  If you do, then you have a life like mine, but I do not have a life most Americans would want to live (this is without even considering the disability).  I don't have "a life like yours". 

CommentID: 78939

1/26/20  2:18 pm
Commenter: T. Thomason-parent

EVV-live-in exemption should be considered and passed!!

EVV as it stands is just one more obstacle that all caregivers must endure. Many of the current regulations, although a bit cumbersome, are understandable in purpose. Caregivers should be checked to make sure they meet basic qualifications in which the disabled population is not put at risk. I see EVV as an unnecessary step due to the facts that 1. the approved hours are never paid out over with the fail-safe that the F/EA's put in place and 2. a person's life does not always run on a regimented schedule-sometimes things happen.

I would dare to say that at least 95% of the caregivers already work over the approved hours so Medicaid is already "getting their money's worth" of the caregivers. Especially the caregivers that reside with the waiver recipients, the EVV is just one more thing to do/remember/abide by for the sake of Medicaid funds being considered for reduction.

  1. EVV takes time- many individuals with disabilities require the attention and hands on are of the attendant. With the CDCN app, the attendants have to type in names (even though the attendant/EOR/consumer are already identified), get signatures, sign at each shift, select start/stop, turn the app on/sign in/ then turn the location services off because the app keeps following many people wearing down batteries, etc.... Of course, this is when the app actually is working.
  2. EVV is disrespectful/dangerous- everyone is at risk for hacking and this is just one more possible door for individuals information/schedule/personal details to be invaded by others.
  3. EVV live-in exemption- this is a no-brainer. Family/live-in caregivers should not be signing in and out when they live with the individual. The waiver recipients and family members/live-in caregivers are "living their life". They are trying to provide care to keep their family members safe, clean, healthy, and happy. This should be considered as a right for the family to live their life, their way....without having to check in and out with an app. They have been successfully entering their times in through the web-portal for the general time they are with their family member. Again, they don't get paid more than the time they are authorized, but I promise they are working more than the authorized hours.


Maybe we can consider EVV for live-in if we raise the hourly rate to $25.00 an hour? Then, it might be more worth the time as that is what babysitters make these days-and they don't have to use an app? (Trying to hold the frustration back is not very easy).

CommentID: 78940

1/26/20  10:39 pm
Commenter: L. Thomas

Live in aides should be exempt from EVV

The EVV was implemented to prevent fraud but it does not capture the extra hours that are worked to care for the disabled when they are ill.  If a doctor agrees with the Plan of Care and the hours are authorized as necessary and a care provider can only record those hours on a timesheet, the EVV does not serve a purpose.  Because I actually am available 24 hours a day, the time I provide care varies from one day to the next.  It just does not make sense to clock-in and clock-out... if I had to clock-in and out everytime I completed a task, most days there would be 20 entries.  Some nights I get woken twice because our son can’t breathe so needs a breathing treatment or his water spilt.  Because a set number of hours are authorized, the consumer should just confirm that their care has been provided.  The EVV is not appropriate for live-in care providers

CommentID: 78941

1/26/20  10:58 pm
Commenter: Ms. Scott, family member

Live ins do not visit - exempt family members

Exempt family members that live together from having to watch a clock instead of caring for their loved ones. 

CommentID: 78942

1/27/20  9:17 am
Commenter: R. Bennett

Community integration. Not with EVV

We were told the app would work anywhere, because attendants all have their own passwords to log in.  However, we discovered this was disinformation.  When in another state, the attendant was not able to log in to the app.  The attendant had to manually enter all hours upon returning home.  All of these manually entered hours, apparently, will be flagged.  The EVV requirements appear to be restricting community integration.  This is unfair to the waiver recipient as Dmas has stated that too many flags could result in a a loss of services.   This does not seem to be in compliance with the Olmstead Act.  Why was this misinformation put out there in the first place?

CommentID: 78944

1/27/20  10:55 pm
Commenter: Heather Mayer

Issues with EVV

The Electronic Verification system has been such a pain. My mother in law cares for my daughter who is in a wheelchair and requires total care, and has been doing so for the past 8 years. My mother in law devotes her life in to caring for m my daughter, and with her being so committed I have been able to further my education and work a full time job. My mother in law is 65 years old, and has a very basic cell phone which already makes it hard with loading the app. With her being here all the time already exceeding the allotted hours and working “off of the clock”,  she often forgets to clock in and out. She also has a hard time with the system being down, and the app being so time consuming taking away from the care she provides that she gives up trying to clock in and out. That in turn messes up the hours, and causes us to spend more time in fixing the problem. I feel that it needs to be another way to keep track of time, and stop people from taking advantage then punishing everyone with this poor system. I am so thankful that my daughters grandmother does care for her because anyone off of the street would not tolerate all of the hassle that comes with a job that doesn’t pay well at all. We need to show these caregivers how much they are appreciated, not show them that they need to be tracked and treated like criminals. 

CommentID: 78949

1/28/20  8:02 am
Commenter: Tina Morgan, concerned parent

Stop STEREOTYPING the family caregiver (exempt live-ins from EVV)

It appears that family caregivers have been stereotyped as common criminals needing GPS tracking through EVV.  CDPA, the low wages that come with the job, and the total lack of benefits, sick leave, retirement, workmen's comp., are throw backs to slavery.  In home health workers are expected to work for basically nothing; drive a client around for no additional reimbursement, and now be tracked like a criminal via evv.  Not only are the attendants now tracked, but the clients are tracked as well through their entire day.  Virginia could exempt live-in providers and help ease this burden.  This isn't stopping fraud; this is making it impossible for the state and consumers to utilize the lowest cost service and treating the family caregiver like slaves and criminals. 

CommentID: 78951

1/28/20  9:20 am
Commenter: Linda Cunningham

Parent and caregiver

EVV- yet another way to hamstring and humiliate those of us who care for our disabled family member. We are  tied to a GPS tracker in order to claim hours we provide care for our son.. the hours still are not accurate as we provide 24 hour care and LOVE. I feel medicaid is working to decrease money spent on caregiving by making it very difficult to adhere to the EVV program tracker. They are saving money because of this, and that is the ultimate goal. It is also nearly impossible to find a new caregiver that wants to adhere to this ridiculous program. We do it because we are mandated to but it is yet another example of how difficult it is to obtain assistance for our son. Lots of pseudo assistance....

CommentID: 78952