Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------------DMAS seems to operate under the assumption that people with disabilities have a very limited existence. There's no respect for our privacy. There is no awareness that we do the same things as people without disabilities, such as work, shop, travel and have families. EVV for live ins steals the autonomy of people with disabilities and our right to live freely. *****It treats us like children who can't manage our own lives.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------ EVV was frustrating. Every day while I was cooking breakfast, I had to stop and clock in. No telling how many eggs I've ruined bc I couldn't get clocked in quick enough. Repeat this scenario every night when I wascooking dinner. Sometimes, I had to pull over on the side of the road to clock in or out. Once, I had to let my child stay on the floor after a fall , because I had to clock in. Please continue to exempt live-ins.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------- What am I, a felon? Put an ankle bracelet on me

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." ---------------------------- We are supposed to buy our own devices, so the state can violate our rights because the state wants to save money so it can pay a bunch of money to the makers of EVV?? Wow.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------- March is Developmental Disabilities (DD) Awareness Month, an annual campaign in the U.S. designed to raise awareness about the inclusion of people with developmental disabilities in all facets of community life, as well as to ***ADDRESS BARRIERS (like electronic visit verification - EVV)*** they face. Established in 1987 by President Reagan, the month celebrates the contributions, and rights of people with disabilities

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------- Loss of freedom Life was pretty good on cdpa before evv for live ins was suggested. I can hire attendants without too much trouble. Now if evv for live ins is forced, my sibling will go without care. I either have to quit work or place them in a nursing home. This isn’t right. I thought the move was to keep them out of institutions. Now, evv for live ins will make it impossible for them to stay home.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------We will probably be sending my child away if evv is forced on live in caregivers. We won't be able to staff out someone for our child if evv for live ins is forced. No one wants to load an intrusive app on their phone. It doesn’t even work on I phones people say. I had to quit my 80k a year job. I can’t take care of my child 24/7 though. I don’t know what I am going to do. Life has been going well since we have had access to live in attendant care. Evv will take that away. I guess my only option when evv is enacted for live ins, is a nursing home.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------ The big thing about EVV for live in caregivers that's causing alarm is the use of GPS tracking and in some cases, cameras and microphones. GPS tracking tells the government where services are delivered...but it also tells the government where disabled people are going. EVV data can show where disabled people go to church, school, or shop, and this compromise of privacy extends to family too.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------------- Electronic Visit Verification for live ins will force disabled people back into institutional settings. Many are opposed to what feels like a profound privacy violation and/or are worried about being unable to find live in providers who are willing to work with EVV. If they don't have private funds to pay for care, an option not available to many disabled people, they will be stuck in nursing homes."

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------- How is paying EVV lobbyists to track live in caregivers in the best interest of the disabled? I live in my own home and am employed. To enable me to continue living independently in my own home and working, I have a live in caregiver who assists me with getting out of bed, bathing, dressing, toileting, cooking, house cleaning, shopping, driving, etc. My live in attendant care is the lowest cost service available to the state. I am in a self-directed Medicaid waiver program, in which I control my own care. I hire my own attendants, set the days and times they work, where they work, and how they assist me. I am extremely concerned about the potential impact of EVV for live in caregivers on my life and the lives of millions with disabilities. EVV lobbyists tacked on EVV to the 21st Century Cures Act. Now, they stand to profit by invading my private life and home and my live in attendant's private life and home. How is paying EVV lobbyists in the best interest of the disabled?

Remove under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------When we tried electronic visit verification (EVV), it did some strange things, so we gave up and used the portal. Please don't force the stress of EVV on live in caregivers. To determine where I needed to be in order for the app to get my location right, I discovered that if I was in my bathroom, the app showed my correct address (anywhere else in the house and it would list at least three different towns, none of which I was ever in). When I went to my bathroom to clock in or out and my correct address showed up, the app told me that I was .7 (or some other random number) miles from my location. :/

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------Please do not force electronic visit verification on live in caregivers. Costs are being overstated by DMAS as purely oppositional. The federal Center for Medicaid Services (CMS) allows Live Ins to be exempted and Virginia has already done so as well. This requirement for Live Ins to use EVV creates an excessive burden for people who live the individual - ARE NOT VISITING- and have the primary burden of care.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------- CD services are the best because you get to stay in your home. EVV is the worst because it erodes CD services. EVV is like the missing ramp to the best facility for the disabled ever built.

Remove under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------- EVV for live ins will pass the burden of Id theft and Medicaid Fraud to shoulders of poor and disabled. Electronic Visit Verification (EVV) for live ins will create a more anxious home space for the consumer and PCA, and it's a violation of privacy. Is it secure? No, it isn't. CMS and DMAS both recently had breaches. EVV will cause layers of dependency on cyber for poor reasons, and this is a junk app. with little security(that is very costly to the taxpayer). This insecurity leaves consumers/participants much more open to identity theft and possibly Medicaid fraud. A large part of the bipartisan support the original legislation was passed on was "stamping out Medicaid fraud". So, the government has done nothing more than put the fraud and identity theft threat onto the shoulders of the poor and disabled that can't afford it.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------------- Dmas in their education sessions said as long as you had a smart device that could connect to the internet at least when timesheets are due there was no need to actually have WiFi services at your home . Again numerous people getting waiver cdpa are very poor and don’t have WiFi . Dmas told them to go to public areas where WiFi is available like the library or Walmart to upload the times captured on the smart devices via the apps . If this isn’t an option is Dmas purchasing WiFi services for everyone? Or punishing us for being poor?

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------------DMAS alleges a savings by removing this exemption; however, 1) These alleged savings were not supported by documentation by DMAS nor by the Department of Planning and Budget. 2) These alleged savings to the Commonwealth will be realized only when recipients do not receive necessary care. 3) Interim DMAS Director Jeff Lunardi said on February 6, 2026 that the removal of the EVV exemption is "not a significant amount of savings". VIDEO 4) The Department of Planning and Budget (DPB) stated that no records were supplied by DMAS to substantiate the alleged savings and the DPB did not produce their own records. So this number has no substantiation.  While the savings are not significant to the Commonwealth, the burden for live-in caregivers is significant and this is why the exemption was granted in 2020 by the Legislature.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-----------------------The electronic visit verification app was such a pain. No telling how many adult diaperings delayed and pairs of gloves wasted, because I had to stop in the middle of clean ups to clock in or out (not to mention the device getting soiled and having to clean it). Then, got distracted by waiting on app updates, having to turn phone on and off to get app to work, etc.. Twice, I've had to dry hands and step away from my child in the tub to clock out. When we took our adult child out of state, I could not log on to the app the entire time we were gone. They say too many manual adjustments to hours could cause the consumer to lose services. This infuriates me!

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------- If it ain't broke, don't fix it. The evv app keeps you glued to your phone and stuck. Most folks don't like being glued to an app. or a phone. They like getting out and getting fresh air and accessing the community not being stuck dealing with all the problems of the app. and the resulting payroll issues. The portal enables one to be free and more independent, the app. keeps one glued to a phone.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------This could happen to you. my knees are shot due to a car accident. this can happen to anyone. EVV is extremely tiresome. having attendant log in for 5 hours machine malfunction, log out, machine malfunction. then log in again for 2hours. log out. then they got to chose which waiver service. then click on the start time then end time. I have to help attendant every time. it is hard enough to FIND an attendant.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------- It is true EVV for live ins will capture GPS location in real time. It is true DMAS and DBHDS has shown to have a poor track record of keeping our information confidential. But that is ok because DMAS doesn't think people with disability are worthy people, it is ok if they are tracked like dogs

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------------Another way to deter people from being attendants. EVV will deter people from becoming home care aides

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------- Tried EVV. Didn't like it. Perfect example: I clocked out at 4:30 and an attendant clocked in at 4:32. It had me out at 4:30 and attendant start at 4:30, which they called overlapping. So the next attendant had to sit and wait all the time to round up. It was nuts.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------- Live-in care-giving services are often delivered by family members or those closest to the patient. These care givers already get visited 2-3 times a month by community services board and the agency overseeing service facilitation and harassment from the mcos and billing through the fiscal agent. These providers don’t visit but usually have given up well paying careers so they don’t see their loved one abused and neglected in a state facility. Now dmas wants to harass them even more.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------------- My live in attendant is refusing to put the electronic visit verification (evv) app on their phone and I dont blame them. The apps take up a lot of space and use up data. It also can access all the information stored on the phone. We are supposed to trust a for profit evv vendor to not access our data or use it other than for it's intended purpose? We have all seen enough bad actors in the tech industry. No thanks.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------- My live in attendant submits their timesheets electronically every 2 weeks. This is works and is good, because it allows for tech issues (which are never ending especially for us because we are not tech savvy) on my end, cable co's end and payroll's end. The attendant cannot submit more than allotted hours. It is already monitored electronically. With evv for live ins, the attendant will be required to remember to clock in and out every day, instead of submitting twice a month (this doesn't allow for tech issues which is nerve wracking to think about). The attendant doesn't have a smart phone, so she'll have to use a landline. These waivers were created to keep individuals/consumers in the community and to save the Commonwealth of Virginia money by reducing the number of individuals going into state care due to lack of supports. With evv for live ins, they will be confined to home oftentimes to ensure their live in attendant can clock in or out.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------ So, out of fear of being flagged, will individuals with live in caregivers be discouraged from thinking for themselves? From changing their minds on the restaurant they're going to or the park visit that was scheduled? "Heck no, we can't go to the next town to sightsee--it's not on your plan of activities and the government might flag it!" That is what evv for live in caregivers will do. It is stripping disabled individuals of their human and civil rights. Why stop at their right to privacy & liberty? Let's remove their pursuit of happiness, too--the life part will eventually follow. And why must it be told when an individual goes to the doctor? How does that not violate the HIPAA law? No one knows to whom this information goes or how it is used--there has been zero transparency regarding this.

I respectfully request that you remove the following language from Item #291 in the budget: “The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments…to eliminate the live-in caregiver exemption from electronic visit verification requirements…” EVV (electronice visit verification) was never meant for the live in model of care. The fed gov't pretty much confirms this with their live in exemption in place. what if an individual is in the middle of a seizure? Or is needing a trach cleaned? Or has vomited and is needing cleaned up? Or is choking? Or is needing to be transported to the restroom? Or has needed an unexpected bath because of an accidental spill or sickness or bowel movement? Is the live in attendant expected to drop everything they're doing in caring for the individual so they can go to clock in or out at the expense of the individual receiving care? There is so much potential liability here and it’s terrifying to think about.

I respectfully request that you remove the following language from Item #291 in the budget: “The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments…to eliminate the live-in caregiver exemption from electronic visit verification requirements…”---------------------Finding attendant care is difficult enough. $13 an hour and zero benefits. And now, they have the potential pleasure of being tracked and monitored (by forced use of EVV for live ins) all under the guise of cutting down on fraud and ensuring the individual is receiving the care they need. It is clear—in reading the fine print—that ensuring quality care is not a factor.

I respectfully request that you remove the following language from Item #291 in the budget: “The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments…to eliminate the live-in caregiver exemption from electronic visit verification requirements…”---------------------- Fraud won't be decreased by forcing evv on live ins. As a matter of fact, there will be an increase in cost for states due to loss of live in attendant care--families that had been helped prior will no longer have assistance and will be faced with difficult decisions on placement. EVV for live ins explicitly removes the entire “self-directed” part of self-directed care. It is now government-directed.

Please remove the following language from Item #291 in the budget: “The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments…to eliminate the live-in caregiver exemption from electronic visit verification requirements…”--------------------- Some of many legitimate reasons for requiring manual entries: I forgot to clock in because the consumer was having a seizure. My phone wasn't working because...well...myriad of technology issues. The app wasn't working (not the attendant’s fault). Consumer had an emergency and attendant chose to care for the consumer rather than electronically clock in at start of shift, making a choice between potentially the consumer’s life or meeting EVV's requirement. (Not a hard decision, and yet, it is “non-compliance” that could lead to the consumer losing services.) DMAS calls all these reasons “non-compliance” and may lead to disenrollment. Why would DMAS force these threats and stress on an already extended family? Why when even the federal government recognizes the need to exempt live in caregivers?

I respectfully request that you remove the following language from Item #291 in the budget: “The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments…to eliminate the live-in caregiver exemption from electronic visit verification requirements…”--------------------- The individuals receiving the care are the true victims here. They will be the ones feeling the brunt of this atrocity, and I, for one, am not okay with that. This EVV for live ins will turnthe individuals’ homes into institutions. The only times the individuals can go out into their community are when the live in attendant is with them. Now, in many instances, they will be confined to their homes.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------Informational material put out by DMAS states that individuals may receive services out in the community, but how does that translate when the live in attendant is required to clock in and out from the individual’s home telephone due to lack of mobile data/cell service? They are tethered to the house. Not everyone has mobile data, and those who don’t are required to use a landline. So, DMAS’ proclamation that individuals will still be able to receive services in the community is utterly misleading!

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------- As a tax-paying citizen of the great Commonwealth of Virginia and the United States of America, I ask you—I implore you—to recognize and take action against the oppressive nature of electronic visit verification (evv) for live-ins and the blatant breaching of human and civil rights that accompanies it. Our most vulnerable population is worth it.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------- I am writing with an urgent request pertaining to Electronic Visit Verification and live in caregivers. There are many who have questions and concerns about this new policy. The 21st Century Cures Act doesn’t mandate GPS tracking. Why has Virginia put this in the policy? Our loved ones are not required to receive services in one location. They have the freedom to receive services at home as well as the community. Many feel that this is a huge invasion of privacy and really doesn’t prevent someone fraudulently logging in or out of a shift. Virginia wants live in caregivers to log in and out on their own devices with no reimbursement of use (many have limited data plans and they pay for their own phones, data, and battery) and many have no device. What is the GPS data going to be used for? Is the GPS location a violation of HIPPA? Won’t the GPS show when the consumer is receiving medical care? Another great concern of mine is that if my caregivers fail to sign in repeatedly or have to edit their entries, that DMAS could remove my child’s waiver. A loss of services that the waiver provides could create a detrimental domino effect to the families of Virginia. Parents or guardians could lose their jobs, because they will have to stay with their loved ones or they will be faced with the choice of institutionalizing their family member.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------- GPS constitutes a search under 4th Amendment. In United States v. Jones, the Supreme Court ruled that GPS tracking constitutes a search under the Fourth Amendment of the United States Constitution. That means for Virginia to track someone, they must either obtain consent or obtain a warrant, for which they must have probable cause to believe a crime is being committed. Unless there is evidence that people with disabilities and their live in attendants are committing crimes, Virginia has no grounds to use EVV to track us or our live ins in our own homes. Further, any consent given could be interpreted as illegally coerced since the consequence of refusing tracking could be the loss of life sustaining health care.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------------- I have employer authority. I need help with my daily activities, but I still work a full time job and I am productive. I am also the consumer and EOR. Self-directed PCA programs specifically state I, as EOR, have "employer authority", therefore, Virginia should have no right to force me to use invasive tracking on my live in attendant and myself. I have lost attendants who have indicated they are not willing to be tracked by GPS. There is no way I would hand that kind of data over to a for-profit EVV vendor. Judging by the recent security breaches at DMAS and CMS, my concerns are already well founded.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------- Folks don't get paid with evv due app. errors. Most live in caregivers cannot afford to do this and will leave. Is Virginia forcing care workers to quit, causing the consumer directed model of service to fail?

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------- DMAS alleges a savings by removing this exemption; however, 1) These alleged savings were not supported by documentation by DMAS nor by the Department of Planning and Budget. 2) These alleged savings to the Commonwealth will be realized only when recipients do not receive necessary care. 3) Interim DMAS Director Jeff Lunardi said on February 6, 2026 that the removal of the EVV exemption is "not a significant amount of savings". VIDEO 4) The Department of Planning and Budget (DPB) stated that no records were supplied by DMAS to substantiate the alleged savings and the DPB did not produce their own records. So this number has no substantiation.  While the savings are not significant to the Commonwealth, the burden for live-in caregivers is significant and this is why the exemption was granted in 2020 by the Legislature.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------- I'm his only worker now. Everyone else has given up thanks to evv for visiting attendants. I've lived with him for 30 years. He lives with his parents and me. Great boss and friend. I am going to have to stop helping them. EVV for live ins will make it impossible to get paid.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------------ You're putting in a tech solution that they're not asking for, for a problem that doesn't exist. Why?

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------------ You want low tech workers to do what? These live in caregivers are hands on persons: the complete opposite of a techie. They are paid the lowest of wages. The majority don't know tech and don't want to know tech. They specialize in people as in not just conversation, as in DOING. Thank God for them! When my father needed care, they were there. I will never forget the care he received! They do the hands on work many do not want to do. They are good with anything people to include the most private and basic of human assistance needs. Why in the world would you ask them to use an application and make their tough, low paying, very important jobs more burdensome? Why?

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------- Could evv for live ins be a way to get care workers to quit, causing the consumer directed model of service to fail??? Wasn't the app designed or funded by agencies??? Wasn't the evv legislation lobbied for by agencies and large corporate nursing homes? Could this be the real purpose of evv??? At first I thought the purpose of evv was to make sure handicapped persons could not give a care worker an extra hour of pay for being willing to come over for an emergency etc. Evv steals your power as a boss to make these kind of trade offs. Of course officials don't know how the real world works.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------- As the EOR, I am responsible for ensuring there is no fraud. Twice a month, my attendants submit online time sheets to the fiscal intermediary payment system. I review each of them, affirm the time sheets are correct, and approve the payment, just like any other employer. For people with intellectual disabilities or dementia, a family member can be designated and trained to handle these duties. A location tracking system is unnecessary and a massive violation of civil rights.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------- I absolutely hate this EVV for live ins stuff. The app we have to use for putting in our hours always seems to lock up or won’t let you add hours. This is too much stress on families whom are already stressed with every day life. I don’t see how it will help deter fraud. As it is attendants are paid poorly and then you throw more crap for them to worry about but don’t want to pay them diddley.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------- please dont send me to a group home. I have been in numerous government placements in my life. This began when I was 7 and entered foster care. I have been drugged, beaten, and raped in those places. I would rather be dead then live in those placements. Would you want to live where staff yells at you all the time. Where you are placed on high levels of psy meds so you don't bother staff? I think it is more humane to do what Hitler did and just put us out of our misery instead of leaving us in group care to be drugged beaten, and raped. Would you want to live a life where you are drugged beaten and raped on a regular basis? You, DMAS, are taking away my option to live in the community and not be raped, beaten, and drugged. This isn't improving care, this is causing my life to suck. This is just so some technology companies can make some money off of the disabled. It is already difficult to find staff for a low paid no benefit job. EVV for live ins it impossible. Maybe DMAS really just wanted to kill us off quicker and help their tech companies make money while they did this to us. :(

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------------- Please don't take away community living....... https://www.youtube.com/watch?v=LfPNBnIpsjU This is a news video of a Virginia nursing home where a woman developed necrotic wounds which lead to sepsis and death from not being moved for days. This is one of many many horrific reports of group care in Virginia. Imagine that DMAS... living in a setting some social worker placed you in, while they pretended you have human rights and you selected the place... then loosing your life cause the place the CSB social worker stuck you had sorry staff. Why do these higher cost placements make DMAS happy? This is just one of many stories that made the news... what about the ones that didn't? these people can't speak for themselves... Please save the lives of people with disabilities and do not allow EVV for live in caregivers...

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------------- It’s not ok to track my disabled child (who is also a minor!) and his live in attendant. We are not criminals and do not deserve to be treated as such. Do not force EVV on live in caregivers. Thank you.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------------- Why is dmas trying to force evv on live in caregivers? It is understandable if there is just cause, because I have done something wrong or have a record, but I don't. I even get a lengthy background check before I can care for my ward. How much vetting will satisfy the state? Each extra oversight ends up costing the consumer in quality of care, because the funds intended to help THEM go to satisfy an unjustified ego or fear rather than a statistically true need for surveillance. Maintain the current live in exemption from EVV.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------------- There is a great deal of concern over privacy regarding everyone's location information and data breaches with EVV for live ins especially when it comes to our most vulnerable: the disabled. There were data breaches with Medicare/CMS and DBHDS in 2019, 2021, 2023, 2024, and 2025. No one being forced to comply with EVV has been given sound information regarding how their GPS location records are stored and protected. There are already at least four DMAS appointed agencies and at least four third parties hired by these agencies accessing this information daily which greatly increases vulnerability. GPS location data is valuable information to marketers, hackers, thieves, home-invaders, etc. Please continue to exempt live-in from EVV, so that they are not living in fear of home invasions, etc....

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------- EVV has caused many issues for myself as an EOR and for my child's attendant. There are constant issues with the CDCN app that cause missed hours. It is not a user friendly process. I have to fight for everything my child has. EVV is just another thing added to our plates to manage. My child is terminally ill. He needs the hours he has, and his aide workS them. EVV is an intrusion on the disabled. It is not anyone's business where my child is (home, community, vacation) when with the aide except me. We have lost aides to previous pay issues due to EVV. They dont get paid enough as is, then have to go without for weeks and months at a time. Do the right thing. Do not force evv on live in caregivers.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------------ Virginia is attempting to cut the most affordable form of care available to the Virginia taxpayer by forcing Live-in caregivers to do something that it knows Live-In caregivers cannot do (EVV- electronic visit verification)? Even the federal government acknowledges they can't do EVV and makes an live-in exception for it. Forcing EVV on live ins will fill up institutions with currently home cared individuals and have taxpayers paying a much greater amount for the care of it's most needy population. How is this helping anyone?

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------why do we have to be tracked like criminals? My brother is now going to be tracked like a criminal? it is sad.. how does this help anything? it is hard enough to hire people to watch my brother... now we have this? please Virginia continue to exempt live in providers.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------------ Sense we tried evv, my patient felt she didn't have the free will to go out and do things the new system locked me out where I had to wait 20 mins to try and clock in and they said 20 mins later that I'm not even getting paid for making 13.00 an hour this required me to have my personal smartphone for work how can evv force me to use my personal phone for work makes no sense period I'm paying my bill and my company offers phones that they charge for this is ridicules we ended up having to use the portal to get a break from the evv nonsense

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------Who is profiting from filling up institutions such as group homes and nursing homes (that will cost the Virginia taxpayer substantially more than community based care which will be completely eroded by EVV)? Who is receiving kickbacks from EVV vendors and the like to force EVV on live in caregivers? LOOK THERE...THAT IS THE FRAUD. The fraud is not in community based care.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------Why are there no names of those who proposed this? Isn’t it odd that a bureaucracy creates a legally binding regulation, with penalties imposed, and no named persons can be held accountable? Something that will affect Va taxpayers (with higher institution costs versus community based services) and the most vulnerable population. Wow. Just. Wow

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------------ I am writing this with tears dripping down on my face! No one know how hard it is to take care of non verbal, austistic and elipesy child unless you have one on your own! Imagine when you are have to clock in or out during the time your son is having seizure, you are so shaking and worrying that he may not come back to life! How can you think of clock in or out ! This is one of the reason DMAS - VA should not be considering pushing EVV on live in caregivers. We have a hard life as it is, please help support us to have energy in our mentally to take care of our childrens! Thank you in advance for your consideration in continuing to exempt parents from EVV!

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------- CMS does not force evv on live ins; why is VA trying to? Va is ignoring the disabled and their families and forcing upon live ins a program which makes their lives with a disability much more difficult. VA didn't have to do this for the live ins and chose to after saying they wouldn't force anything at the state level the fed gov't did not require.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------the app. doesn't always work and it causes more work. Once, attendant tried to clock in several times. after several tries for over an hour, the thing said it is now submitted twice; so now the pay will be held up for the attendant and phone calls will have to be made. who gets paid for all the work to deal with the app?

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------- EVV is a burden to families and caregivers who are already maxed out. Adding a clock in responsibility is unhelpful. My child requires a demanding level of care and it makes no sense for our live in attending to be working on admin duties while expected to perform personal care. Many times, taking the time to click in would pose a safety issue, and we will not be able to take the time to do it. We should not be penalized for this. The system is too slow; not like a time clock where you could swipe in and begin work. I need my employee to attend to my medically fragile child not to have to worry about clocking her time. please consider what a burden this might be to families. Thank you!

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------------Live ins should continue to be exempt from EVV log ins. EVV just makes it more difficult for everyone involved, and it’s not a job that can be time quantified as clearly as EVV is set up for. This is all hard enough, help make this easier for all the dedicated live in caregivers.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------- Are our loved ones confined to a bed? Are they not free to enjoy and experience their communities? Why are we even being asked to input a location for beginning and end of service hours? It’s absurd. We have jumped through hoops constantly to prove that our loved ones are disabled (many since birth) and are going to be disabled for life. They are constantly creating barriers to civil liberties and the intent of these waivers was to give them access to community increasing quality of life.. I have chosen to try to give my son experiences to give him joy, those experiences come with community living, educational opportunities, which give him the least restrictive life possible. He is not a prisoner of this state, but often this is how we feel. He deserves to have the same freedoms as people who do not have disabilities. He deserves to be a part of his community and to experience a quality life regardless of disability. He still requires my constant care and supervision, and that should follow him, regardless of where he is at any point in the day. His disability is not going to improve, but his quality of life should never be an expected or mandated sacrifice.

Remove under Item #291; REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------- The participant's level of needs are barrier enough to services. The EVV app is full of glitches and doesn't always clock in or out as it should. We had to resort to computer portal to enter time. The attendant waited to be paid for an 10 hour shift, because the EVV tacked on an extra 15 minutes to the shift which caused the whole shift to be rejected. Then, the EOR had to make phone calls to get it fixed. Not many live in attendants can afford to go without pay and will choose to quit over these errors especially if they get blamed for the errors. The state of VA should be ashamed of making decisions that make it harder to hire and keep a live in attendant. The participant's level of needs is already barrier enough. Piling on more barriers is a violation of the consumer's rights to access services and live in the community.

I respectfully request that you remove the following language from Item #291 in the budget:------->>>>> “The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments…to eliminate the live-in caregiver exemption from electronic visit verification requirements…”-----------------------EOR's are free help. They volunteer to deal with so much. There is always some complication with EVV which will make things worse for EOR's. It was difficult enough for EOR's to deal with the fiscal agent, state, service facilitator, and the portal, but if EVV for live ins is inacted , EOR's will have to deal with EVV and everything else. Being overwhelmed with a disability is bad enough, but add to that already having a full time job with overtime, volunteering time as EOR, and EVV for live ins and you have the perfect storm for EOR's. How can one expect them to stay and do this for free? We will lose EOR's over EVV for live ins.

I respectfully request that you remove the following language from Item #291 in the budget......: “The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments…to eliminate the live-in caregiver exemption from electronic visit verification requirements…” Live ins are family caregivers and those who have provided their homes to persons with disabilities are making one of the ultimate sacrifices. There are no paid holidays. Their job is NOT 9 to 5. It is 24 hours availability 7 days a week. There is no salary: $13 an hour (out of that $13 an hour comes all transportation for the person with disabilities as well). They are not paid anywhere near the hours they work. There are no sick days. They work while sick. There is no job security. There is no pay security. The many different agencies tied into their pay (Community Services board, Service facilitators, employer of record, dept. of social services, dept. of medical assistance services, DBHDS, or the fiscal agent) can neglect a simple step and they lose pay and spend hours correcting other's errors. There is no healthcare. There are no bonuses. There are no benefits. With evv for live ins they would need to post times at least twice daily at arbitrary times (although they work 24 hours) to a very difficult system that will GPS'ing them like criminals. This is after they go through extensive background checks. Why would the state force evv on live-ins when the federal government recognizes live-ins as the exception and exempts live-ins because they do not "visit" and provide 24 hours care? *******Because the six figured, salaried state staff with "abled" families making the rules could care less what a live in goes through in one day.

I respectfully request that you remove the following language from Item #291 in the budget: “The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments…to eliminate the live-in caregiver exemption from electronic visit verification requirements…” EVV is a horrid App, it drained my battery, despite settings with its constant pinging. For Live-ins, we work 24/7 and not the small amt. of hours we are paid. My adult child seized once late at night while i was trying to use EVV. Did I clock in? No. Did I clock in the two hours I stayed awake making sure he didn’t cluster? No. Am I ripping off Medicaide? No. You are going after the wrong people. We can’t even make a decent living wage on $13/hr with the limited hours we are assigned. Medicaid fraud is perpetrated by Companies, not Live-In Attendants. Why are WE being treated as criminals out on parole with ankle bracelets disguised as EVV and causing wear and tear on our own devices? The App was time consuming, invasive and should be dismissed.

I respectfully request that you remove the following language from Item #291 in the budget: “The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments…to eliminate the live-in caregiver exemption from electronic visit verification requirements…”------------------- Ratios are the most valuable asset when it comes to people caring for me. I currently get one on one care with consumer directed care, but EVV for live ins will take that away. There should be a premium put on ratios. I have been in many institutions; they are bulk care. The persons working there are there for a paycheck and not because they have an interest in my well being. There were little protections from the people in the homes that I stayed in. Once, I had an elderly man in a nursing home corner me in a room and offer anything I wanted if I came to his room. No staff were around to help me. Once a man showed up naked in my room, and it appeared to be an accident until it happened one too many times. Every place I have been in smelled like urine and feces. The cushions in shared rooms had stains on them and staff sprayed them with fabreeze which didn't help. Once a violent resident backed up their wheelchair to mine and started punching me from behind. Staff laughed and did not come to my aid. Staff had a smoking area right outside the building, so I couldn't open my window and get fresh air. My neighbor next door smoked marijuana in his room, and the staff knew it, because I told them the smoke got in my room and they never did anything to stop it. I don't want to go back. I love my home. Don't make me leave it. My friend cares for me now, and I live with them in their home (they make me feel like it is my home too). **I cost the state the least by being in consumer directed care. i don't want to be in assisted living because of EVV for live ins. I understand that noncompliance with evv will result in the "offering of other services". I know that means institutions because there are no other options. Please keep my ratio low and help me stay in my home by not forcing evv on live in caregivers.

I respectfully request that you remove the following language from Item #291 in the budget: “The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments…to eliminate the live-in caregiver exemption from electronic visit verification requirements…”--------------------------- Please help the government to do the right thing and LISTEN to the disabled. That doesn't mean listening to agencies representing the disabled that are out of touch. That means listening to the persons that actually have to do the work and those actually receiving the care. Possibly a lot of money can be saved if PERSON CENTERED PRINCIPALS are used to communicate with the disabled and care givers.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------It costs SIGNIFICANTLY more in healthcare dollars and taxpayer money to have individuals with disabilities housed in institutions (i.e. hospitals or nursing homes) vs. living in the community. This is what the end result of EVV for live ins will be in Virginia. Numerous people who were living for years in the community will be placed in higher cost settings with far less freedom and poor quality lives. EVV for live ins makes hiring and keeping attendants impossible. EVV for live ins will cause attendants to not get paid. Everyone is being threatened to have their consumer directed services taken away, but it is impossible to use EVV because of all the issues with the applications. PLEASE CONTINUE TO MAINTAIN THE EXEMPTION FOR LIVE IN CAREGIVERS FROM EVV.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------ If CMS is exempting live ins and VA currently exempts live ins, why is dmas doing the most to hurt it’s most vulnerable residences by requiring EVV for live ins? I have yet to see an answer why, so only the worse can be assumed. We are framed for failure.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------- As guardian of an adult with special needs, life is very exhausting. EVV is an unnecessary, added trauma.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------------ We fee like animals dropped off at the pound with evv for live ins. You see, a person making a quick, and easy decision for them, can ruin the poor animal's life by dropping them off at the pound on a whim. That is what is going on here with DMAS trying to remove the exemption for live in caregivers. They are making an easy, quick decision for them with no real substantiation for what they are doing and it is going to wreck havoc on the disabled around Virginia FOR LIFE. Please, be considerate and maintain the exemption for live in caregivers from EVV.

I respectfully request that you: Keep the EXEMPTION from Electronic Visit Verification (EVV) for live-in caregivers, in line with CMS recommendations! Include $250,000 one time capital funding for the Autism Community Hub planned by the Autism Society of Central Virginia. Funds are in the House Budget and need to be added to the Senate budget. This Hub will be a model for other communities to establish a centralized, inclusive space to offer programs. Keep all developmental disability waiver funding included in the Senate Finance report. Include rate increases for Respite and Companion services,

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------There has got to be a better way for live ins than EVV. Dealing with a disabled family member makes life very stressful. As attendant, my job is caring for them 24/7. Because my family member will be living with us for the rest of their life, EVV is an unnecessary burden. When we tried EVV, during Christmas and New Year's vacation with extended family, I had to interrupt special outings and activities to deal with the clock. A few times, the app didn't work right and I had to stress during holidays trying to get it to work and wondering if I would be paid or investigated or both. That is not a way to live a life especially during the holidays. My family member goes with me wherever I go. EVV is a burden in our situation.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------- From Charlie Carr's Blog A BRIEF REVIEW OF THE ORIGIN AND POTENTIAL TRAGEDY OF ELECTRONIC VISIT VERIFICATION (EVV) 02/18/20 "During a congressional oversight committee hearing the Congressional Budget Office (CBO) was asked about the $125 million pay for and how it was determined. CBO had no credible evidence to support the allegation that there was a high level of fraud, waste and abuse in the personal care service program. Based on that, the panel declared the projected "savings" as flawed and unacceptable. Since that time no substantive/credible finding of fraud in the consumer directed personal care services program has been made available by CBO yet states continue to interpret location as using GPS and biometrics in the name of program integrity. Program integrity is code for fraud, waste and abuse." Charliecarr.com

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------I am a care recipient and EOR. I will find it very hard to hire workers if EVV is forced on live in caregivers. *****Why is it that I pay for a large portion of my care every month with MY OWN FUNDS through patient pay and I have no say about the forced use of EVV on live ins? My personal funds are spent down to COLA levels to pay for a large part of my care and I have no say. ****I am really not sure that is legal!

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------------- Why is DMAS trying to force live ins from exemption from evv? Federal evv requirements do not apply to caregivers providing service in the shared home of the consumer and caregiver. Personal care services rendered by an individual living in the residence does not constitute an in home visit. You are asking live in caregivers to essentially make up hours when in all actuality they are available 24 hours per day, but only get paid for a irrational set of hours. You are also asking for them to neglect the consumer and their needs to spend countless hours messing with a system that doesn't work.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------------- When I used electronic visit verification (EVV), it messed up my hours all the time. I wouln't get paid for God knows how long; my hours were messed up due to the app. I had bills to pay. I had to switch to using the portal. The app not only invades the privacy of the disabled, but it also puts the disabled at risk of losing their caregivers. Participants will lose their attendants because many attendants live from pay check to pay check and will be forced to quit. They will have to work where they will get paid in a timely manner.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-----------------------Requiring participants, employers of record, and their live caregivers to all have smart phones or tablets is not well thought out at all. These are Medicaid recipients and persons making $13 an hour with no benefits. These folks must purchase certain phones/tablets only, since the app is only available in certain app stores and the device must have GPS capability. They must have a data plan or, at minimum, a landline phone. Who is footing this bill? The attendant on $13 an hour? What happens when the consumer or EOR can't afford a landline phone bill? What happens when the phone breaks? What happens when the phone or app or both malfunction? Who should be responsible for the expense of these items, ensuring that there are no technical matters and repairing/replacing said items immediately? Maintain the EVV exemption for live in caregivers. Don't fix what isn't broke.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------------A perfect storm is brewing. An additional consequence of electronic visit verification (EVV) for live ins is that it adds yet another layer of bureaucracy to programs and recipients and includes privacy rights infringement for workers to each state’s already overburdened Medicaid agencies. EVV for live ins is time consuming, invasive and pushing away qualified workers and further exacerbates the existing crisis in recruiting and keeping good personal care services workers nationally. Most states that administer the consumer directed personal care services program either through HCBS, MCO or some other method are already experiencing a serious worker shortage that negatively impacts disabled clients and elders who rely on these workers to live in the community outside of institutions like nursing homes. In several states, disabled and elder personal care services consumers have defaulted to emergency rooms and short term nursing home stays because they can’t find adequate and appropriate workers.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------The apparent justification for GPS tracking is to prevent fraud and abuse in Medicaid personal care services. However, anyone who would advocate for such a system clearly lacks awareness of who receives Consumer Directed services and why. The majority of us have severe physical disabilities. We need and will always use the hours we receive. Even though, it would be my dream to do anything with legs (even a janitorial job at a beer fest or college dorm is a beautiful dream for me), I'm not going to suddenly get up and walk or suddenly not need help using the bathroom. EVV for live ins is an additional burden we do not need.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------------- The state is mandated to consult with stakeholders including consumers, their reps, and caregivers regarding EVV for live ins especially when EVV for live ins is currently exempt with Virginia and CMS. By federal law, the state is mandated to consult with stakeholders, which includes consumers, designated representatives, and employees completing the work in addition to EVV vendors.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------- EVV can be traced back to a money grab by technology companies looking to make a profit off the disabled (it is always the disabled first; YOU are next). This has nothing to do with fraud (except that of EVV companies) and helping people with disabilities. Evv for live ins is attempting to track people with disabilities in their own homes every. single. move, each. and every. day. If I didn't have live in CDPA, I couldn't have attended a family wedding. I have live in CDPA, because I qualify for nursing home care level services. CDPA allows me to live in the community and saves taxpayers money compared to nursing home costs. Without it, I would be waiting to die in a nursing home (and spending a lot more of the taxpayer's $). But, it isn't right that my every move is monitored, so EVV tech companies can turn a profit. CDPA has very low fraud. EVV for live ins will make sure most of the people getting CDPA in Virginia WILL NOT continue to get the care they need.

Remove under Item #291; REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------------Many people will leave the field over invasion of privacy in the home, gps tracking in the home, and app unreliability for live in caregivers. This needs to be considered when states have stakeholder meetings. We must work to keep the privacy of all citizens including people with disabilities, their families and their caregivers. We have a crisis with the shortage of healthcare workers as it is. This technology and use of geo tracking can create a catastrophe within the home care community. The loss of providers could cause people to end up in institutions or nursing facilities. This alone could be detrimental as there are not enough nursing facilities to house the thousands of clients in each state the rely on HCBS waivers.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------- We can't keep an aide. EVV is a deterrent for visiting aides. No one wants to have trackers on their phone. Low pay already has us down to family members for live in aides. We need another aide, but can't find someone to fill the gap that lives out, and now, we will have no hope of even trying to find someone who will live in if evv is forced on live in caregivers. Thank you for listening.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------- What I am angry as heck about is being forced to be GPS'd and spied in my own home with a unrelieable/faulty system to care for another person. I give up so much of my life to help someone else. So many unpaid hours already just to keep them out of a facility (that doesn't even exist because there are not enough facilities to take people). Now, they want to force me to give up more of myself for this? It is so frustrating. It feels like rape, because it is not necessary (not required by the fed gov't and CMAS), and so forceful on people who only want to care for others

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-----------------------------I had to get a live in attendant because of problems I had with EVV when I had two live out attendants. Often they would deny the original submission, because attendant 1 clocked out at 12:45 and attendant 2 clocked in at 12:45. They adjusted attendant 1's shift but shorted their hours. So, I would have to spend the rest of the day on the phone to sort it out and sometimes it was never sorted out. One attendant just got paid less. Please maintain the established regulation for live in attendants exemption from EVV.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------------- ADD: Skimming pay. Is this the "fraud" everyone is looking for (that DMAS is committing)? There are plenty who will not put up with not being paid and the skimming of people's pay that EVV for live ins will cause. How much "fraud savings" by cutting time with a minute here and a minute there, before we have no one to care for our loved ones? People will quit over it. No one would ever tolerate the missed wages, app glitches, repeated phone calls and emails, online corrections, threats for online corrections, service facilitation agency errors, DMAS errors, case manager errors, last min. mtg. cancellations, late arrivals to mtgs, payroll agency errors, all four agencies playing "hot potato" with the service plan causing delays, no one caring about the delays and loss of pay due to the agencies not processing the plan in a timely manner, privacy breaches of all your info., prior authorization hang ups, threats of losing services, etc... that so many live in caregivers endure. Don't make CD services worse by adding a faulty program called EVV.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-----------------------------Here is a problem my live in had when trying to use the evv app.....When they clicked for time entry or payout report, it said to contact administrators? I emailed and called with no response. How can anyone allow all these issues with the app and demand us to use evv for live ins?

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------------------ Dmas is just trying to get us all dead quicker by taking away the only useful service they offered (which happens to be the most affordable for the Virginia taxpayer). Besides making money for technology companies, the only other purpose evv for live ins serves is to make it impossible to hire self selected live in providers.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------------------- I could not use the evv app. but I tried to. Not one time did my live in attendant get paid on time when using EVV app. The app will boot you out. It will make shifts disappear. It will not pay a whole 8 hour shift if the shift went over the hours by minutes. It’s hard enough having special needs kids , even harder finding live in attendants, but it would be literally impossible to keep them with EVV for live ins. An error on their end can cause lost pay . I can’t loose my live in attendant or I don’t have a job. I can’t keep my live in attendant when they can’t even get their whole paycheck they worked for . They already get paid pennies for what they do, then for their paycheck to always be messed up when they use EVV makes them late on their bills and they will have to find work elsewhere. This app clearly isn’t doing any good. Please don't let exemption from EVV for live ins be taken away. All of us will suffer greatly.

I respectfully request that you remove the following language from Item #291 in the budget: “The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments…to eliminate the live-in caregiver exemption from electronic visit verification requirements…”---------------------- Why is DMAS willing to change a disabled person's life to the point where many will end up in nursing homes for no substantial gain? Or is there behind the scenes gain? Kickbacks from evv vendors? Profiting from the filling up of institutions such as group homes and nursing homes? WHAT IS THIS? ------->>>>>DMAS alleges a savings by removing this exemption; however, 1) These alleged savings were not supported by documentation by DMAS nor by the Department of Planning and Budget. 2) These alleged savings to the Commonwealth will be realized only when recipients do not receive necessary care. 3) Interim DMAS Director Jeff Lunardi said on February 6, 2026 that the removal of the EVV exemption is "not a significant amount of savings". VIDEO 4) The Department of Planning and Budget (DPB) stated that no records were supplied by DMAS to substantiate the alleged savings and the DPB did not produce their own records. So this number has no substantiation.  While the savings are not significant to the Commonwealth, *****the burden for live-in caregivers is significant and this is why the exemption was granted in 2020 by the Legislature.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------------- The bureaucracy of living with a disability is difficulty enough not to add in electronic visit verification (EVV) for live in caregivers. Living with a disability is a never ending paperwork nightmare. We are vetted and verified a thousand different ways. Year after year. We are constantly proving a disability that is obviously never going to improve, only progress. Hiring attendants constantly. How many others will not be able to cope with this additional burden? How many of us will end up in nursing homes and for what? A program that is not required by CMS and is unnecessary? Please continue to exempt live in caregivers from EVV.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------------- Please, come to my home and see how live in caregivers live. Why is it our lives get more and more complicated on top of everything we already deal with?? It continues to blow my mind on how this all keeps getting more and more complicated for us to just simply care for our children. It’s hard enough trying to manage everyday life and then throw in the disabilities part. Now its EVV for live ins, then its a request for paperwork that you've done already and then its a statement or letter from yourself and others. It’s unbelievable the hoops we have to jump through to make it work. I have written a letter twice for renewals because they want to take away caregiver hours. Each time I have to explain I am a single full time working mother of twin autistic boys. I need all the help I can get. Feel free to come over for a day and see how we live! Please keep the exemption for live in caregivers from EVV.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------------------- For the short period I tried the electronic visit verification app, I was bewildered at all the problems. For example: Once, I submitted a question through the "contact us" on the app about them changing my hours from 40 hours to 39 hours and 45 minutes. I filled out all the requested information. I got a reply back saying I did not give attendant Id, birthday, and ss number. They didn't ask for these items on the form. After 3 weeks, needless to say, they never answered the question. This is a bungled system. Please don't not force evv on live in caregivers. Continue to exempt them as it currently stands.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------------- Please continue to exempt Live Ins from EVV. Why must a family of a consumer have to clock in with an app that most days would show our location two houses down? How is that a verification and why do I need to verify? This is where I live with my disabled daughter that I care for daily. Why must you make it harder on the families? Thank you for your time.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------------------My visiting caregiver has been frustrated over and over by the app. going down. It will go down at the most inconvenient times...sometimes for every day of the week. My live in caregiver uses the portal and posting the live in's time is never a stress. Please do not add to my troubles by forcing this EVV app on my live in caregiver. Continue to exempt live in caregivers from EVV.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------------- We are in a caregiver crisis that EVV for live ins will make worse. According to an AARP study, in 2010 there were 7 potential caregivers for every person over 80. The study reveals that by 2030 the ratio will decline sharply to 4 to 1 and by 2050, 3 to 1. Those who qualify for the state’s Medicaid program for in-home care are already having a very difficult time finding workers to meet the demand. EVV for live ins will make it impossible for consumer directed services to keep up with the demand/needs of the disabled. Please, continue to exempt live in caregivers.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------------- When people think of caregivers, they often think of adults taking care of their elderly family members, but that is not the reality for many adolescents and young people who are forced into distressful situations when loved ones are diagnosed with cancer. There are so many situations when family must step up or no one else will. Sure, they can abandon loved ones in nursing homes or other state placements. But we know as a society, people don't get good care there. There are a number of situations where people in all stages of life step up to care for loved ones unable to care for themselves independently. In the few situation where Medicaid is able to step in and help the family from becoming homeless, consumer directed care steps in. EVV is taking away the entire consumer directed care system. Continue to exempt live in caregivers from EVV.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------- EVV systems for live in caregivers erode the intent of consumer-directed services, walking us back in time 40 years where disabled people are no longer in control of their private lives. Without consumer-directed services or adequate home care employees to assist us in our homes, many disabled people will have no other option than to be placed in a nursing home. This is the antithesis of the spirit of independent living and would violate the Supreme Court Olmstead decision, which requires states to offer services in a home and community-based setting when they also provide nursing home care. Continue to exempt live in caregivers from EVV. Thank you.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------------------ My house is not an outpatient hospital or nursing home. There is never a reason for the government or their EVV vendor to have access to the private dealings of my life solely to prove I am disabled and in need of assistance. The very fact that I’m alive today to write this piece means my live in caregiver completed the tasks with which I needed help for the day. And I’m completely capable of continuing to verify that my employee performs the work I direct them to do. Please continue to exempt my live in caregiver from EVV.

Remove under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." I am a parent of a person with disabilities and maintaining the EVV exemption for live-in caregivers is important to me because Live-in caregivers do not "visit," and the use of a "visit" monitor system does not capture the ongoing presence and involvement of the caregiver. Care is continuous, not clock-based, and using EVV misrepresents how care actually happens and forces caregivers to log artificial “shifts” that don’t reflect reality. EVV is designed for an attendant who “visits” to provide intermittent support. Live-in caregiving is continuous and cannot be chopped up into visit tasks. If there is a need for oversight, care recipients and families can easily verify that care occurred. Live-ins are on call 24/7. Shift workers are not on call and clock out at the end of a shift. Live-ins cannot clock out. It’s unreasonable to expect a live-in caregiver to clock in and out for every issue addressed around the clock. The EVV system was created to track shift-worker attendant time and movement to help prevent fraud. There is no potential fraud component for live-in caregivers. EVV tracks location. The live-in caregiver will be at the location, so there is no point in the location tracking aspect. The task tracking is easily verified by other means. Live-in caregivers are working around the clock far more hours than they are being paid. Live-in caregivers provide care intermittently throughout the day and night Live-in caregivers respond to unpredictable needs such as: seizures, elopement, behavioral crises, toileting, medications, and much more. Overnight and on-call hours are hard to document. Live-in caregivers must remain available at all times and may be awakened multiple times per night for seizures, medical needs, or elopement. Live-in caregivers are tied up with all too common urgencies and emergencies around the clock, day and night. They shouldn't be forced to direct their energy to a time clock and away from the person receiving care. EVV does not add anything to the quality of care or even accountability, since care recipients and families can easily verify that care occurred without EVV. Many live-in caregivers are family members who left paid employment to provide care and save Virginia significant institutional care costs. Requiring these live-in caregivers to use EVV will push many toward institutional care instead. It shows bad faith for Virginia to now remove that exemption, and it will make caregiving feel punitive and distrustful.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------- Many people are happy with online timecards, which they say are accessible and work well; and as the ones receiving services, they have no incentive to collude with providers to lie about the hours of care provided, as they’d only be defrauding themselves. Plus, with live ins, we get more hours of care out of live ins than what the live in is paid. We get care when we need it this way. EVV is fraught with problems and will eventually cause more persons to be forced into institutions. Please don't let this happen. Please save the evv exemption for live in caregivers. Thank you.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------- EVV for live ins doesn’t address fraud or quality of services. A ton of money will go to the EVV vendors, who continually spend a lot of money lobbying for EVV. Don't mess with the evv exemption for live in caregivers.

Please remove language from Item #291 in the budget: “The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments…to eliminate the live-in caregiver exemption from electronic visit verification requirements…”---------------------------- DMAS alleges a savings by removing this exemption; however, 1) These alleged savings were not supported by documentation by DMAS nor by the Department of Planning and Budget. 2) These alleged savings to the Commonwealth will be realized only when recipients do not receive necessary care. 3) Interim DMAS Director Jeff Lunardi said on February 6, 2026 that the removal of the EVV exemption is "not a significant amount of savings". VIDEO 4) The Department of Planning and Budget (DPB) stated that no records were supplied by DMAS to substantiate the alleged savings and the DPB did not produce their own records. So this number has no substantiation.  *****Once EVV for live ins is enacted, it will erode the most affordable care program for Virginia taxpayers and force persons with disabilities back into institutions. This will greatly affect the Virginia taxpayer, because institutions cost substantially more than Consumer direct care. Any "savings" will be eclipsed by the flooding of institutions. It amazes me that the representatives of our state fail to recognize that caring for our own family members is the most cost effective solution for those who are able and every means should be taken to make it easier for these parents instead of increasingly difficult. There should be no limit as parents are on duty 24/7 and even if parents were paid 24/7, it would still be more cost effective than living in a state funded institution. And, the level of care is far superior to most institutions and the family gets to remain at home where they are comfortable and wish to remain.

remove the following language from Item #291 in the budget: “The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments…to eliminate the live-in caregiver exemption from electronic visit verification requirements…”---------------------------- DMAS alleges a savings by removing this exemption; however, 1) These alleged savings were not supported by documentation by DMAS nor by the Department of Planning and Budget. 2) These alleged savings to the Commonwealth will be realized only when recipients do not receive necessary care. 3) Interim DMAS Director Jeff Lunardi said on February 6, 2026 that the removal of the EVV exemption is "not a significant amount of savings". VIDEO 4) The Department of Planning and Budget (DPB) stated that no records were supplied by DMAS to substantiate the alleged savings and the DPB did not produce their own records. So this number has no substantiation.  *****Once EVV for live ins is enacted, it will erode the most affordable care program for Virginia taxpayers and force persons with disabilities back into institutions. This will greatly affect the Virginia taxpayer, because institutions cost substantially more than Consumer direct care. Any "savings" will be eclipsed by the flooding of institutions.

I respectfully ask that you remove the language in Item 291 directing the Virginia Department of Medical Assistance Services to seek federal authority to eliminate the live-in caregiver exemption from Electronic Visit Verification (EVV). Live-in caregivers are not visiting workers coming and going from a job site. They are family members or caregivers who share the home and provide continuous support throughout the day and night. Requiring them to “clock in and out” through an EVV system in their own home does not reflect the reality of how this care is delivered. The current exemption recognizes that live-in caregiving is fundamentally different from shift-based services. Removing it would create unnecessary administrative burdens for families already providing the majority of care and support. Please remove this language and maintain the existing live-in caregiver exemption.

I respectfully request that you remove the following language from Item #291 in the budget: “The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments…to eliminate the live-in caregiver exemption from electronic visit verification requirements…”------------------------ The Centers for Medicare and Medicaid Services (CMS) says that live-in caregivers are not considered visitors and allows states to grant an exemption from the EVV requirement to record hours in an EVV device for live-in caregivers. Please preserve the live in exemption from EVV.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------------------- Since you passed legislation granting live-in caregivers this exemption effective January 1, 2021, live-in caregivers have been able to provide round the clock care without the constant interruption of clocking in and out. They can't be expected to clock in and out based on the small amount of hours they are paid, because they do not watch a clock and provide care around the clock. EVV electronically verifies that home and community-based services are delivered to the client. This is easily verified by a live-in caregiver by other means than using EVV to clock in and out for shifts and tasks. Requiring a live-in caregiver to use this system is burdensome and takes the focus away from providing care which can be dangerous. Please continue the exemption from EVV for live in caregivers.

The Centers for Medicare and Medicaid Services (CMS) says that live-in caregivers are not considered visitors and allows states to grant an exemption from the EVV requirement to record hours for live-in caregivers. This is important to me because I am the live-in caregiver for my disabled daughter. Requiring live-in caregivers to use EVV will impose real harm on people with disabilities and their families and caregivers. Live-in caregivers do not "visit," and the use of a "visit" monitor system does not capture the ongoing presence and involvement of the caregiver. Care is continuous, not clock-based, and using EVV misrepresents how care actually happens and forces caregivers to log artificial “shifts” that don’t reflect reality. EVV is designed for an attendant who “visits” to provide intermittent support. Live-in caregiving is continuous and cannot be chopped up into visit tasks. If there is a need for oversight, care recipients and families can easily verify that care occurred. Live-ins are on call 24/7. Shift workers are not on call and clock out at the end of a shift. Live-ins cannot clock out. It’s unreasonable to expect a live-in caregiver to clock in and out for every issue addressed around the clock. The EVV system was created to track shift-worker attendant time and movement to help prevent fraud. There is no potential fraud component for live-in caregivers. EVV tracks location. The live-in caregiver will be at the location, so there is no point in the location tracking aspect. The task tracking is easily verified by other means. Live-in caregivers are working around the clock far more hours than they are being paid. Live-in caregivers provide care intermittently throughout the day and night Live-in caregivers respond to unpredictable needs such as: seizures, elopement, behavioral crises, toileting, medications, and much more. Overnight and on-call hours are hard to document. Live-in caregivers must remain available at all times and may be awakened multiple times per night for seizures, medical needs, or elopement. Live-in caregivers are tied up with all too common urgencies and emergencies around the clock, day and night. They shouldn't be forced to direct their energy to a time clock and away from the person receiving care. EVV does not add anything to the quality of care or even accountability, since care recipients and families can easily verify that care occurred without EVV. Many live-in caregivers are family members who left paid employment to provide care and save Virginia significant institutional care costs. Requiring these live-in caregivers to use EVV will push many toward institutional care instead. It shows bad faith for Virginia to now remove that exemption, and it will make caregiving feel punitive and distrustful. Requiring live-in caregivers to use electronic visit verification (EVV) would return Virginia to a system it dispensed with for live-in caregivers in 2020. CMS recognizes that EVV is a burden for live-in caregivers and allows this exemption. Please remove this harmful language from the final Budget

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------------------There are a lot of problems with EVV for live in caregivers that have disabled people raising concerns. One is the rigidity of the system, which in some cases could require people to wake up in the middle of the night to sign off on hours. For others, people who perform multiple kinds of services may struggle to classify them. What happens when someone helps someone with toileting, washes some dishes, and then preps some medication? These may be classified as different services, and have to be logged independently. Problems with logging services accurately are a big concern. It’s already hard to find qualified workers and EVV for live ins will be a deterrence. Protect the disabled trying to stay in their homes and do not take away the exemption from EVV for live in caregivers.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------------GPS tracking of live in caregivers tells the government where services are delivered…BUT it also tells the government where disabled people are going. EVV data can show where disabled people go to church, school, or shop, and this compromise of privacy extends to family too. Our families don't deserve this in their homes. Don't let this happen to your family. Maintain the exemption of EVV for live in caregivers.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------EVV for live ins causes harm. I am particularly troubled by a provision that has not received much attention: the requirement that states begin effectively geo-tracking people with disabilities who use personal care services through Electronic Visitation Verification (EVV) systems. I have spent the past month gravely concerned for my future. With massive cuts to Medicaid, my ability to receive the necessary supports to live and work in my community is at great risk. EVV for live ins will place me further at harm.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------------How would you feel like if you needed to verify your identity and physical location with your state government via a GPS-enabled biometric device every time you exercised a civil right? And if you didn’t properly check in, you ran the risk of losing that right — or of losing your health, or even a family member’s life? Maintain the live in caregiver exemption from electronic visit verification.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------- What would it feel like if the government outsourced the responsibility for managing a forced check-in process to a third-party contractor that had a backend database prone to leaking protected personal health data to other people? What if the recipient of the contract to build those devices and maintain those databases was a major lobbyist behind the law establishing this obligation? Would you be angry? Please stop taking advantage of the disabled and continue to maintain EVV exemption for live in caregivers.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------The core purpose of in-home live in care assistants is to ensure that differently-abled persons and their families are can live the fullest life possible in their own community and not in an institution. EVV for live ins will hinder this in many ways. Please continue to keep the exemption for evv for live in caregivers. Thank you.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------- Where does Virginia think live in caregivers are? They LIVE in the home. They do not "visit". They have a very serious job of which, if they weren't doing it 24/7, someone would be neglected, or worse, expired. Virginia sends professionals to visit the home at least twice a month and insists on the disabled sitting through countless meetings yearly regarding a their needs, appearance, health, supports, etc....Are these people in the program neglected when you see them? Are they dead? Oh no? They are healthy, alive and thriving in their home environment which is being threatened by EVV for live ins. Live ins are vetted on location/habitat by several means. EVV and the small amount of hours assigned to a live in do not fit a busy live ins' round the clock job and will, by the live in's inability to stick a very small amount of paid hours and a strict schedule, cause the live to not be paid and the disabled to lose their care. Please let exemption from evv for live ins stand as is. Thank you.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------------- At first glance, EVV seems like a simple distributed time clock, but it also represents a deceptively intrusive tracking of the lives of Medicaid recipients. Live in caregivers for the disabled are required to work varied, sporadic, and flexible hours around the clock (even though the hours they are paid do not reflect this) and in a variety of locations. Recipients of these services are people who may need help getting to a doctors appointment one day, or getting around the mall another day, aid with prevention of elopement, getting up in the middle of the night, or myriad of emergencies and extreme situations/needs. EVV does not fit the schedule a live in or the disabled care recipient live by. Keep the live in exemption for live in caregivers.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------EVV establishes distrust as a baseline in a relationship that is fundamentally about trust. When caregivers log into a GPS-enabled EVV device, they also provide a precise and analyzable location history of the clients, and by implication, they also provide a record of private and Constitutionally-protected behavior. This is one of the tricks of data analytics, especially when enhanced by machine learning techniques: data is never just about the thing you originally think it is, it is always also about what can be mechanically inferred. EVV adds an extra layer of intrusion because it unilaterally alters the labor-management relationship between PCA and client while offloading audit responsibility to the client. Leave live in caregivers exempt from EVV.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------- According to ADA, governments aren't supposed to create programs that are beyond the competency of the participants. EVV is very difficult for even skilled tech savvy clients, eors, and attendants to use. EVV for live ins will make consumer directed services unusable to people who do not have a smart device, computer, wifi access, or a landline. DMAS doesn't seem to understand people using this service are typically poor. Many elderly parents are able to keep disabled, adult children home under this service. EVV for live ins will take that away. No amount of "education" and "training" is going to fix this issue. Please, continue the exemption from EVV for live in caregivers.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------------- We want the same rights free range chickens have. Chickens get free range. They are not GPS'd or geofenced and can go anywhere. We want free range. We want to be able to be and go anywhere. No geofencing or GPS tracking! Keep the exemption from EVV for live in providers.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------Please exempt live in caregivers. Location not being captured in rural areas. Even though the software has offline capability, some of our patients live in such rural areas that the location can't always be captured. And when it is, it's not always accurate. DMAS states providers will not be reimbursed unless this information is in the claim file. We can't just not provide care to patients just because they live in remote areas-many without landline phones-as that would be considered neglect. DMAS has not been clear on what to do in these scenarios and we are just trying to provide the best care possible for the patient because that's what they deserve. EVV has been very burdensome and time consuming-the patient/client is what truly matters. There needs to be some better preparation/direction on what to do if the location can't always be captured.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------------- Did the electronic visit verification (EVV ) vendors not make enough funds off of the true "visiting" caregivers? So, now they want to repurpose their app for people it was not intended for, that do not visit over greed? It is dangerous to ask someone who is mentally and physically busy 24 hours per day, who is available at every problem big or small, including emergencies, to drop what they are doing and prove they are visiting their own home. Actually, that is impossible to do because no one can visit their own home. EVV vendors, go and find another group to take advantage of and quit profiting off the weak and voiceless. Leave live in caregivers alone. Thank you.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------------- EVV is not good to push on live ins. EVV will make my life with a disability much more crappy... things were going pretty well. Now I am at risk of nursing home placement. I would rather die. I can no longer hire attendants as they don't want to work these days and now under these problems with EVV for live ins, it will be next to impossible to hire someone. Please continue to exempt live ins from electronic visit verification.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------Please maintain the exemption for live in providers. there is no reason live in providers cannot continue to be exempt.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------------- EVV hurts the disabled. EVV for live ins will limit the lives of the disabled and track them in their own homes. It isn't helping anyone except EVV vending companies' bottom line. Keep the exemption from EVV for live in caregivers. Thank you.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------DMAS is telling people if they just educate the eors and attendants more then all these problems will be solved. That the people can be indoctrinated into understanding the necessity of EVV. But the thing is EVV isn't needed for live ins. It is a burden to the disabled and especially for their 24/7 caregivers. Many people were using consumer directed services without a problem. Now they can't because hiring staff is impossible. No one wants to work and get time cut over EVV problems. Address the real issues DMAS. People can't get the free phones. People will have to purchase a dedicated smart device and a wifi service now just to stay out of a nursing home. Stop acting like all these people with disabilities are just stupid. We fully understand what you are doing to us. Continue the exemption for live in providers.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------- EVV is bad. DMAS should at least continue to exempt live in providers.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-----------------------------Live ins should continue to be exempt from EVV.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------------- CMS says Virginia doesn't have to have live in providers do EVV. Virginia said they wouldn't do anything more then the federal law requires. Virginia has exempted live ins since 2020. How could continuing to exempt live ins from EVV cost anything? There are several costs/losses for taking advantage of the disabled and forcing EVV on live ins.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------------ 23 years ago, my child was strangled by the umbilical cord during birth, leaving her brain-damaged and paralyzed. "She will be a vegetable the rest of her life," said doctors. "Put her in an institution". When my child was 10, we asked a top University if there was anything to help her communicate. "No way. There's nothing going on in her brain." But, we noticed she laughed at funny stuff. Turns out a lot was going on in her brain. With a computer that allowed her to control the cursor by touching a switch with the side of her head, our child was finally able to communicate. DMAS is attempting to take away our freedom and autonomy with EVV for live ins. Please, continue to Exempt Live in Providers .

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------- This hurts my son. just trying to stay out of a nursing home. we are even more humiliated by the attempt to track us 24/7 now. EVV harms the disabled.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------------- Olmstead was supposed to help us stay out of facilities. EVV for live ins will make the lowest cost stay at home option impossible to use. Was Olmstead even informed? Did the Olmstead people think this would help? It does not help. Save the status quo: keep live ins exemption from electronic visit verification.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------------------- We have live out attendants right now. We want a live in. We have desperately been trying to find one. There are so many things about the job we must warn them of that make the job difficult (like not being paid for errors of several agencies involved in the consumer direct process - something out of our control). Often times, that is when they decide not the take the job is when we warn them; however, if we don't tell them, then they end up leaving after they do discover the problems. I am sure we aren't the only ones struggling like this. EVV will make it impossible to hire and keep live in attendants, so we will never get one. Please don't remove the evv exemption for live in caregivers. Thanks.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------- No to EVV for live ins! Electronic Visit Verification is Incompatible with Independent Living! Currently live ins are exempt from EVV in virginia. Let's keep it that way! Thank you!

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------Ed Roberts had severe disabilities and founded the Independent Living Movement. Ed was assisted by personal care attendants for most of his life and neither he nor his attendants were subjected to technical surveillance and prohibitive policies that monitored their every move. Consumer directed used to be an utterly simple and deeply humane program that fostered living and letting live. In fact, it was precisely because he enjoyed the unhindered freedom to move and function that he accomplished all that he aimed for himself and us, his brethren, in the Independent Living Movement. His revolutionary Independent Living way of life was based on the notion that we may not be able to do many physical things for ourselves due to our disabilities but that we are still able to accomplish them with the use of assistive technology and the unhindered help of personal care assistants who respect our wishes and preferences in how to do things our way, when and how in the secure privacy of our home. The original consumer directed was a very delicate and symbiotic relationship of respect and trust between us as personal care recipients and our personal care providers. The secure and private set up of that relationship is another form of the God-given right to life, liberty and the pursuit of happiness enshrined in the US Constitution. Please don't take away our independence by forcing EVV on live ins. Keep the current exemption from EVV for live in caregivers as it is.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------- The Consumer Direct Program is only funded with Medicaid dollars to make sure that disabled people don’t die, starve or suffer neglect because there is no one to feed, bathe and take care of them. The use of government funds to provide the personal assistance services should not force the loss of civil liberties the way this intrusive EVV system would be if forced on live ins who have no choice but to rely on personal care services. I’m sure that Taxpayers who fund the most affordable care program for the state - consumer direct program - would strongly oppose the use of invasive technologies that stifle the very basic freedoms that threaten their future when perhaps they themselves have to use the program. Don't let EVV happen you and your family.

Consumer directed care was not designed as a business arrangement between animal handlers and a herd of cattle who have to be taken care of, an arrangement that businesses can manipulate with as much technology and control as they want. Yes, providing essential personal care services to human beings calls for funding the way we answer with food the problem of human hunger. But It does not give the government the right to violate our humanity and control and herd us like captive cattle. The outrageous insistence of government to force EVV on us or else is just truly sinister. Will this be another cottage industry to the home care and IT industries?-----------------------------------------No one cares or is fighting for those of us with disabilities. ACLU, DREDF, NDRN need to see more blood spilled before they'll consider it a privacy rights or Olmstead violation, respectively. EVV for live ins harms us. Maintain the exemption for live ins from the harmful EVV.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------------------------- Consumer directed care was not designed as a business arrangement between animal handlers and a herd of cattle or an arrangement that businesses can manipulate with as much technology and control as they want. Yes, providing essential personal care services to human beings calls for funding. But, It does not give the government the right to violate our humanity and control and herd us like captive cattle. The outrageous insistence of government to force EVV on live ins is just truly sinister. Will EVV vendors be another cottage industry to the home care and IT industries (in other words: another of many vampire agencies profiting from the disabled's misery)?

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------- There is a ton of controversy that surrounds that fact that your phone comes GPS track enabled. Wherever the phone is, it can be tracked by someone that has the software to do so. While this is helpful in instances of missing kids, criminals, or a lost cell phone, many others feel as though their privacy is being violated with tracking capabilities. Tracking a cell phone without a person’s knowledge is against the law. If you have the ability to track a phone with GPS, you may be tempted to break that law and violate the phone owner’s rights. Perhaps the biggest problem or complaint with phone tracking capabilities is the invasion of privacy. Hackers, thieves, and other dishonest people may use your phone GPS tracking software against you. If they want to break into your home or cause you harm in another way, they can easily track where you are at any given moment. So, while you are out at the mall, they are at your house taking everything you own. DMAS wants live in caregivers to give up their rights against illegal search and seizure to use EVV (electronic VISIT verification) to prove that they "visit" their own home??? Unbelievable. Maintain the exemption from EVV for live in caregivers.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------------- From CMS Centers for Medicare and Medicaid Services (federal government) Informational Bulletin, August 8, 2019: EVV requirements do not apply when the caregiver providing the service and the beneficiary live together. PCS or HHCS rendered by an individual living in the residence does not constitute an "in-home visit". Maintain the exemption of live in caregivers from electronic visit verification (evv).

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------- Live in caregivers and EOR's put up with so much. This is one of many scenarios: They receive two scheduled visits (scheduled at the convenience of the service facilitator and the case managers) twice a month where the Service Facilitators and the Case Managers are often no shows, are late sometimes by an hour, or cancel at last minute. So, the planned meetings are rescheduled at the convenience of the service facilitators and the case managers. The live ins and EOR's may as well of had four meetings, because the live ins and the EOR's planned and got ready four times. Another fun one is when the service facilitator or case manager never schedules, shows up out of the blue and expects you to be there. When you are not there, they write you down as a "no show". Both service facilitators and case managers will LIE about a EOR or live in just to get themselves off the hook as in the above scenario where they wrote the live in and EOR down as "no shows". Then, they have the live in and EOR sign on a tablet at the meetings they finally arrive at for God knows what because you don't get a copy and they don't tell you what you are signing, so you are probably signing that you were a "no show" and don't even know it. Then, your case managers and service facilitators are constantly (6 months or less) having turnover, so the fun learning curve begins all over again and some of the people they hire (by their unprofessional ways) make you wonder how they passed the background check. Please don't add more of a burden to EOR's and live in caregivers by forcing them to say they visited THEIR OWN HOME....just try getting the SF and CM to respect the live in caregivers and EOR's at little more...that will go much further than EVV for a live in caregiver.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------------ Many folks do not put apps on their phones at all because of how invasive they tend to be (not matter what data mgmt. "claim" they do or do not do). All of these systems bring into question data security during transmission and storage of information. Who has access to the data regarding our whereabouts? What are they doing with that data? Have there been breaches in the past (the Centers for Medicare & Medicaid Services - CMS - reported that a single hack compromised the personal information of 3.1 million individuals)? Protect persons with disabilities privacy and maintain EVV exemption.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------------- Several times and with several people I know of, a caseworker or service facilitator doesn’t put in the plan for services in a timely manner and services lapse. They usually get back dated (sometimes for upwards of 2 months waiting on a pay check). With evv, how will this work? You can’t send the time through the payee system until DMAS approves the hours cause they will just be permanently rejected. This program is difficult enough for live in caregivers not getting paid for months at a time not to have to burden them with EVV too. Please continue to exempt live in caregivers from EVV.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------- Tried EVV. Hated it. One annoying app. issue among many was when assisting attendant with logging out on app. Went through whole process, hit ok, end, etc.. like we always did. The next day? Still logged in. Made no sense because we know how to log out. So we had to continually adjust. Just a sample of many annoying app issues.

Remove under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------------- CMS/fed govt does not require EVV for live ins, because they know it would be a burden to live ins. In their impact statements, Virginia said they would not require more then the federal guidelines stated. By attempting to force Live Ins to do EVV, DMAS is not following this statement. Please maintain live in caregivers exemption from Electronic Visit Verification (EVV).

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------------- Many folks receiving community based care,where dmas is attempting to force EVV on live in caregivers, pay a good portion of their own funds towards their care. It is called "patient pay". These folks deserve a say in how the program affects them. If you are a care recipient in this program, you know that EVV will cause a shortage in live in caregivers, and for many that means going back into institutions. That is a deadly quandary for a care recipient. Why would dmas, knowing this, force something unnecessary on the disabled that would erode the community based program? It is without any reason, so there must be other intentions that ignore the costs to the care recipient, ignore the care recipients' financial contributions, ignore the care recipients' input, and ignore the cost to the taxpayer (community based care is least expensive care option for the state). Kickbacks, bribes, EVV vendors push for more clientele, profiting off filling up institutions, etc?? One wonders.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------- The federal Center for Medicaid Services (CMS) allows Live Ins to be exempted from EVV and other states have done so. Mainly because they know the burden EVV puts on a live in provider. LIve ins ARE NOT VISITING.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change.------------------------ We were flagged by EVV and had to resort to the portal to gain sanity. 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 were 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?

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Forcing a live in caregiver to use EVV is like 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?

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------- EVV in all waiver families' homes is a big pay day for evv lobbyists and those being paid by EVV lobbyists. No Thanks.

Remove under Item #291 harming the disabled: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------- The Electronic Verification system was not easy to use. The portal proved to be much easier. My live in attendant devotes her life in to caring for my daughter, and with the attendant being so committed, I have been able to further my education and work a full time job. My attendant is 65 years old, and has a very basic cell phone which made it hard loading the app. With her constantly here, already exceeding the allotted hours, and working “off of the clock”, she often forgot to clock in and out. She also had a hard time with the system being down, and the app was so time consuming taking away from the care she provides that she gives up trying to clock in and out. That in turn would mess up the hours, and cause us to spend more time in fixing the problem. I feel that the portal is sufficient for live ins to keep track of time. I am so thankful that my daughters attendant does care for her, because most people 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.

Remove language under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------- It appears that family caregivers have been stereotyped as common criminals needing GPS tracking through EVV. The low wages, lack of benefits, sick leave, retirement, workmen's comp., etc...are throw backs to slavery. Workers are expected to 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. Virginia needs to continue to 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.

Remove language forcing disabled into institutions and costing taxpayers more under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------------- If EVV for live in caregivers is enacted, we will be tied to a GPS tracker in order to claim hours we provide care. the hours are not accurate as we provide 24 hour care (but paid for much less). Medicaid is working to decrease money spent on caregiving by forcing a faulty device like evv on live in caregivers. They think they are saving money because of this, and that is the ultimate goal. Sadly, this is the cheapest care program available, so in the long run, when this program is gone, the state will spend more tax dollars to pay institutions for all care-giving. It is also nearly impossible to find a new caregiver that wants to adhere to this ridiculous program.

Remove detrimental language under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----------------------------- We have had difficulty with the evv app and switched to the portal. Half the time my attendant couldn't punch out or stop the clock, the other half the time, he couldn't get it to start. It never picked up the location correctly, inside the house it read service location unknown, but if you walked to the neighbors driveway, it will pick up. This caused a lot of stress when we were trying to clock him out in time, or was 30 minutes of wasted time trying to get it to work. I am not sure I understand how this is an improvement over the portal which has always worked well. Thank you.

Please remove language under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------- EVV for live ins is going against ADA law by not providing unfettered access to the community! It also infringes on the rights of consumers and attendants. It's also a HIPPA violation. Please, do not force that cumbersome tech on live in individuals - they have it hard enough.

Remove language under Item #291 (harms persons with disabilities) REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------- I can understand clocking in and out of a normal job with a regular time clock (not evv which is faulty), but caretaking of people with special needs is especially taxing, and adding the burden of entering time worked in to EVV for live ins is a stress that live in attendants really do not need. In addition, the amount of time spent trying to adjudicate everyone's problems with the EVV app must be incredibly expensive to the State. The question is, why are we doing this? Does EVV really cut down on fraud for live ins (they live there which has to be proven any time upon request)? It just makes the lives of the people with disabilities and their caretakers that much harder.

Remove hindering language for the disabled under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."-------------------------- CMS (fed govt) exempts live in caregivers from EVV, and since 2020, Virginia has exempted live ins and said they would never go above CMS guidelines. However, now, after many attempts to stymie LRI's, Virginia is suddenly attempting not to exempt live ins . This is a drag net of which not just LRI's are affected; many persons that have made this program a success for over 20 years are being attacked too with forcing EVV on live in caregivers. VIRGINIA, PLEASE, DON'T THROW THE BABY OUT WITH THE BATH WATER. THIS IS NOT THE WAY AND WILL END UP COSTING THE TAXPAYERS MORE IN INSTITUTION COSTS WHEN EVV erodes further what was a great and most affordable form of care for the state.

Remove crippling language under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------- DMAS says, "Person centered planning requires really listening to the person" DMAS is not practicing what they preach. No one wants their daily lives and their habits tracked with EVV. No one. To have live-ins do evv, is essentially having their lives tracked. It is an invasion of privacy. Live-ins do not visit. Their job is 24 hours a day and yet they are given a set of hours to clock in and out. It is nearly impossible to clock in and out at set times when a person is providing 24 hours care. The clock becomes more important than the person cared for. The state is making a live-ins's job so difficult, that they may be forced to quit. Institutionalization will be the ONLY option at that point. With the majority of live-ins receiving two in-home visits per month and countless ongoing evaluations, how much oversight and expense is enough (yes, EVV costs the taxpayer)? EVV has created unnecessary burdens and additional bureaucracy just to clock in and out. This is not a simple clock in and out procedure. There is always some difficulty with EVV which can be attested to simply by using a search engine and reading complaints readily available. State officials have been contacted was well concerning this cumbersome, burdensome process.The waiver program was put into place to allow independence and community access to persons with disabilities. EVV is a hindrance to partaking and enjoying community access. Do not say they can go anywhere with the app and clock in and out! When folks are stuck at home, because they dealing with the app., the bureaucracy, and fallout EVV causes, they are NOT in the community! Crippling the disabled by making it more difficult to maneuver their daily lives is not an option.

Please remove wrong language under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."'"" I'm a mother. I participate in community directed services , evv for live ins is a nightmare, you are subject to penalty when the app or global internet is not working, my area has poor internet service, I had to discontinue verizon and my phone service to afford cox for reliable internet ,it cost more and still the app often times isnt working appropriately, it doesn't allow for corrections or it's own errors of not being able to pick up signals via the internet, the failure to recognize that the internet global communications is not a direct landline but signals by air wave to satellite and towers is weakness. Not every locality has a tower near by and weather and global positioning also affects the GPS tracking systems, we have had to purchase a cell phone and pay for cell phone service costing yet more money for use of data, data plans are expensive I have tried diligently to comply.. The tracking device wants an explanation of why I'm in my bedroom and not living room.. Entries for hours worked are often dropped by app or not picked up. Attendants are being blamed, Attendants are paid not on time and or not at all. a trip to the little gym is a nightmare explaining why we are not home. 1 minute past allowable 8 hours, is a day without pay, Forcing the disabled and handicapped to participate in this program is penalty to this population. it doesnt prevent fraud, but causes more problems for the populations and recipients of services. it already is tough getting help with no benefits at all. the Rights of live in caregivers need to be preserved and advocated for. I say to you at what cost do we have to continue to be treated like second class citizens? And at what cost would you yourself like to be tracked and have yourself answer for your every move. anyone can but in a entry and anyone can still commit fraud , this is a possibility. For a few who did such a thing should we all be held accountable for their crime? the evv is nothing more than a good talking point and with all the troubles I have experienced, institutions are now a consideration. we are tired and beaten up and loosing the community directed objective , no one cares and shifting values and objectives have caused this population more harm than good. A,gps tracker and a app isn't a prevention program, but puts more stress on a already stressed population and its caregivers.

Remove verbage under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--------------- evv is going to contribute to the shortage of care providers. Please continue to exempt live in providers so my loved one doesn't end up in a nursing home to suffer a miserable existence.

Remove language under Item #291 making a disabled person's life and needs second to a clock: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." xxxxxxxxxx Live in aides and parents should remain exempt from EVV. This system was designed for an aide who comes and goes each day at certain times, not for an aide who lives with the person being cared for and is available 24 hours a days for any need. The disabled person has needs that do not happen on a clock and must come before the nuisance and burden of making a call and answering multiple questions to clock in/out or waiting on a cell phone to come on and an app to load and checking multiple boxes just to clock in and clock out.

Remove language putting the disableds' lives in danger under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Why put the health and safety of a disabled person in jeopardy, so a live in aide can clock in/out, so they don't get a red flag? The system is severely flawed and punishes a disabled person for being disabled and needing help. Instead of encouraging and removing barriers so the disabled can thrive, this system is trapping them at home, tracking their movements and threatening their health and safety. Why threaten a disabled person's Medicaid status, because of an arbitrary system of red flags?

Remove the language under Item #291 that will force those with disabilities back into institutions *******REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."************** I care for my friend's child with disabilities. My home is now the child's home and they are treated just like family. Evv will turn my family's life into an episode of the Twilight Zone. Imagine the Walton's having to clock in and out for one child every day many times per day. That is what is going to happen to families when EVV is forced on live in caregivers: The Walton's meet The Twilight Zone. I thought the most trouble would come from dealing with a disability or from the countless in home visits by agencies and the many evaluations and meetings! We are considering the unimaginable: of letting this child go into the system! DMAS is simply "changing the channel" when it comes to the needs of this child.

Remove the harmful language under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." EVV is a burden for live in caregivers. Please do not for this on them especially when it is not required or needed. For the small amount of time where I tried EVV, here is what happens when using: The app burns the phone battery quicker. One of my child's attendants logged out at the end of the shift ,but it kept running after the attendants left. The next day, the attendant saw the shift completely screwed up and had to correct it manually. This was a system error. We went on vacation with an attendant but had no wifi and thought we were able to enter the time manually at a later date. But, we were told too many manual entries could cause my child to lose services. What else is one to do if there is no wifi? The attendant's phone broke and this person could not use evv for several days. It is harder to keep track of the hours to make sure you do not go over. It definitely is complicating things for people with disabilities.

Remove under Item #291 and continue to exempt live in caregivers from EVV just as the federal government has exempted them because they know the burden EVV will cause live in caregivers-------------------- REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."------------------------ It is sad that DMAS is trying to force EVV on live in providers. Asking them if their job started and ended in the same place?! They live at their jobs. Their job never ends. Their jobs are 24 hours availability (even though they are not reimbursed for 24 hours). Their homes are provided to someone with disabilities at the lowest cost and least responsibility to the state. Stop the nonsense and continue to exempt live in providers just as the federal government through CMS has exempted live in providers because they understand the burden EVV would be for a live in.

Remove language under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change The EVV system is flawed and poorly put together. I have used 4 different browsers and had problems with them all. You login and the screen sits blank/white. This happened repeatedly. I was advised by payroll to utilize Mozilla, which I hate. It worked a couple of cycles, and then began having issues. The system did not save my brother as consumer/recipient of services, nor either of the caregivers/providers. That took multiple calls, when no one was answering the phones. Multiple complaints were filed by email, which most concerns were not addressed. If you can't provide consumers with a browser friendly program - it should not be utilized! Caregivers who are not computer saavy, nor adequately trained struggled to learn the system. When an error is made, it is not easy to fix, to which that burden usually falls back on the EOR who is unpaid. Now any other entity that pulled this would have the labor board investigating. If a caregiver has to log in to register missed time - the drop down list is extremely limited. Why can't they type in their own reason for why they were not able to log the time? So, in order to get paid, they must choose from a drop down list that may not apply. But if you want to get paid, you must pick one, all by repeatedly being reminded of "fraud"!!! My brother has a caregiver for respite. He is allotted certain hours. So if that caregiver is kind enough to take him out of town for the weekend, logging in ONLY the hours assigned - yet has him out of town, how the heck is he supposed to sign in/out from home? There is NO option on any list for that. EVV says they are not monitoring location - well then they shouldn't need access to phone locations, NOR designate them. How about when you call in - the phone system option - and the system does not recognize your number, or cuts you off - there's a whole list with that as well. Then there are the caregivers! One of my caregivers stated, "it's getting so it's not worth it anymore." With what is paid to these folks - it's no wonder good help is hard to find, Talking about policing - what about those on welfare/food stamps? What's in place to monitor them? NOTHING! But an individual who is DD, will not recover, is not a result of a choice they made, yet need to be monitored. THAT IS our government trying to find reasons to not provide services to our mentally handicapped. it is unacceptable to make the DD guinea pigs!!!

Remove paragraph under Item #291 and help save community based services: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----- Virginia should continue to exempt live in providers from electronic visit verification. People are saying that because of evv their attendants are not getting paid. Good attendants are being lost and our loved ones will end up in crowded, highest cost, state run facilities. Please stop this from happening. Please let the governor know what is going on.

Remove language under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." - - - - Why make the majority of good people feel underappreciated? The state is fortunate there are nice people that care and will put up with the intimidation. The evv threats for live ins are going to chase away all those that have self respect and would rather not be treated as criminals.

Remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." This is from a friend who has visiting attendants for her family. Our family uses live in and the following situation would be unbearable for a live in: "EVV is like slow and painful torture. The systems keep being tweaked, so it is hard to keep track of how it operates. We are constantly having to phone to fix things and when we do as instructed the attendant is still not paid for many weeks. With the old system, the attendant entered info once a week and the Employer of Record (EOR) approved once a week. With this EVV system the attendant must do 10 entries (as opposed to 1) and the EOR must do 5 (as opposed to 1). What good is a system that does not work? Why are we fixing something that isn’t broken? People are loosing attendants and it is already so difficult to find good people! Pretty soon there will be very few services available for the Virginia Medicaid Waiver. The Independent Auditor needs to know that even though services are listed as available, they are really not available (few providers or sponsoring agencies). EVV disables the disabled."

Remove words under Item #291, so we can keep our adult child home. REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." 1) when hiring a visiting caregiver, EVV Often malfunctions causing caregiver to not receive pay on a regular basis. Often times not being payed at all. 2) after exhausted search to locate a caregiver, the Caregiver moves on to another job because of pay issues with EVV. 3) elderly live in parents getting injured having to care for their adult disabled child 24 hours a day with no help. 4.) Add the cherry on top: EVV for live ins and it is a nursing home as the only option.

Remove language under Item #291, so that I don't lose my live in caregiver. REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." I hire attendants I have visiting attendants and I also have a live in. My selection for attendants is becoming smaller and smaller due to evv. No one wants this on their phones. I may be relying completely on the live in at some point and need the relief of exempting live ins, so the participant can stay out of a nursing home. The Cures Act was supposed to help drug addicts, not harm people with disabilities. Right now, live ins are easily listed/notated with the SF and FA hired by DMAS and should continue to remain exempt. I don't know how I am going to keep the participant out of a nursing home if they force evv on the live in.

Remove language under Item #291 harming people with disabilities: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." I cannot take much more of the EOR duties and evv for live ins will make it worse. It is just too much for a non paying job. Finding qualified help for $13 an hour is beyond difficult, especially if you live in a rural area. The live in attendants do not always get paid for their work. Numerous calls and emails to payroll go unanswered, take weeks to answer, or they leave you hanging by acting as if their hands are tied and referencing their IT is in a foreign country. My services facilitator acknowledged that a lot of people have often not been paid, and there are so many issues with evv that prevent it form working correctly.

Remove language under Item #291 that punishes the disabled: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." If evv is forced on live in caregivers, we will have to spend time away from those who need care in order to manage this system that doesn't work. My disabled roommate's live in caregiver isn't comfortable putting the app on their phone. I don't blame them! My nonverbal roommate "consumer/participant" doesn't use a phone, so we will have to buy one. The only time we will use it is for evv. We will have to constantly monitor it to make sure the battery is charged and we are keeping up with data requirements and updates. That might not seem like much, but in my life with a business to run and my roommate's life as a live caregiver, every second counts. i hear the app rarely works, so we will be taking time away from our roommate to try to get the live in attendant signed in or out. If it isn't correct, it will take my volunteer time on the portal or phone to correct it. Our attendant roommate won't get paid for the time they are trying to sign in. It is not like an office where you can come in and grab a cup of coffee, see what's going on with your boss, and organize your desk before starting a project. Our attendant LIVES HERE and is ALWAYS ON DUTY. Yet, they are supposed to ignore important needs/emergencies to manage this faulty evv system. i understand the system shorts time as well. Everything about this is designed to punish the disabled and the people who work and VOLUNTEER hard, for little or NO pay, to take care of them. We will lose them to an institution. Then, everyone will lose.

Remove under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Already know of people places in nursing homes because she of evv... it is too complicated and costly for the low skilled low paid workers to follow through with.

Remove language under Item #291 causing live ins to be subject to impossible apps: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." I am a live in mother/caregiver of a person with special needs and there is no room for electronic visit verification in our busy lives. I have tried it out, and this evv cell phone app was a nightmare. I had to mark on , mark off every day even though I watch my child 24 hours a day. I was constantly setting alarms to make sure I mark on and off. . In-home caregivers need to stay exempt as they are now. Thank goodness they are exempt and have a portal which works to mark time. I once had to pull over on the side of the road to complete the long app from Consumer Direct. I would like my son to have another visiting attendant but the mark on/mark off on the exact minute is so difficult that we have not been able to hire anyone. Thank you for your time.

Remove under Item #291 language that harms VA families: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." families don't need evv. iving with a disability means dealing with constant paperwork, never ending meetings, several government agencies, and having to sit through a litany of endless evaluations. this is on top of a disability. how many folks will not be able to manage the additional burden of evv? disabled families don't tend to live by a clock. they are just struggling to live. please exempt families from this burden. they don't visit

Remove language under Item #291 calling for tracking of disabled at a higher degree than sex offenders: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."- - - Is anyone aware that one of the apps being used for consumer directed EVV is telling people their tokens have expired? That is how messed up this is...1. federal government does not require gps location; only a note the service is taking place at home or in the community.....2. Live-ins can are exempt by the Federal Government and they are already identified by the fiscal agents … 3. Why is it ok to track people with disabilities to a higher degree than sex offenders?

Remove culling the herd language under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----- Thanks for nothing DMAS. Live in Caregivers work with people, not computers. Thanks for trying to make the their job a lot harder by attempting to remove the EVV exception for live ins. Live ins do not visit and the middle name of EVV is "visit". Why? To remove the newest live ins, LRI's? To cull the herd? This is not making any sense unless there are other motives. Please, do not remove the exemption of EVV for live in caregivers that was established in 2020.

Remove language forcing needless tech on the disabled under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." - - - There are enough problems with the portal. It is too hard to handle a disability along with trying to manage EVV. The app is too hard to work with. Please continue exempt live ins from this burdensome process.

Remove language causing the loss of volunteer EOR's for the disabled under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." We are losing our volunteer EOR over EVV for live ins. The EOR is already upset because the irs will only allow one EIN per sole proprietor and the EIN is connected to both the business and the care giving. They are afraid their volunteering their time and social sec. # to be EOR for the state's benefit will look like they have a domestic employee and this could increase their business liability insurance. Once the payroll agency didn't do their job and the state came after our volunteer EOR (the payroll agency and EOR share a role); it took all we had to get the EOR to stay after that incident. The EOR is doing a great volunteer service and without them, we will have to resort to an institution. *****Please stop stating that the volunteer EOR use their phones or their communication devices for this crazy EVV and app. It will be the nail in the coffin for our volunteer EOR to quit volunteering their time and the person cared for could end up in an institution. The state can only ask so much from a volunteer.

Remove language damaging to lives of the disabled under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Evv for live-ins is dreadful! When we first signed on a live-in, we used EVV, but quickly had to resort to the portal to get reprieve and clarity to record hours properly. With EVV, the live in had to clock in and out in our own home six times a day. Every day revolved around alarm clocks going off, making sure gadgets were charged and working, etc... so that the live in didn't miss certain times (it is easy to miss times, because the live in works around the clock, their tiny breaks are unpredictable, and their minds and hands are very occupied all the time - it is like asking a cop, nurse or doctor to clock in and out when they are already at their jobs working). I get nauseated thinking that my child and his live in caregiver will be put through this the rest of their life just to get disability assistance.

Remove language under Item #291 harming VA taxpayers and the disabled: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." This is important because EVV is NOT FREE. Oh, they didn't tell you about the cost to the taxpayers and the profits of the EVV vendors for forcing EVV on live in caregivers (WHO DO NOT VISIT - THEY LIVE IN THE HOME - LITTLE PROOF TO BE GAINED HERE)? How about the millions in savings that taxpayers reap every day that community based care (live-in caregivers) is utilized over agency based care such as nursing homes and group homes? How about the loss of Community based care due to EVV and how this will hurt the VA taxpayer? They didn't tell you? Check your sources, check who is profiting, ask questions, get answers and realize you are not only harming the disabled, you are harming Virginia taxpayers when you enact the above language!

Remove language treating the disabled like criminals under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Isn't there enough on people that are disabled and the live-in attendants caring for them without having extra burdens placed on them such as this restrictive, socialistic evv? It is damaging to the disabled community. What kind of law is this attacking the disabled as if they are criminals? Live in attendants must have strict background checks, so they are not criminals. This is not helping the disabled community, but it is creating more chaos. WE ARE NOT CRIMINALS.

Remove under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." I don't want to ever be in an institution. evv is very time consuming. it makes it difficult to hire live in attendants.

Remove language under Item #291 that will diminish community support staff for those with disabilities: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." This is important because Virginia does not have enough community services staff and they will be limiting their staffing pool with EVV for live-ins. The income is $13.88 per hour with no benefits. Many are weighing the cost/benefit and realizing the job is not worth it. Many live-in attendants don't know how to use a smart device, so they go to jobs where they don't have to use one. Some clients can't get the free Medicaid phone, because they don't have a credit history. Live-in attendants will be asked to make phone purchases just to clock in and out (with visits when they don't visit )which is lowering the staffing pool even more. Asking a live-in attendant to download an app. onto their personal phones is asking them to pay for clocking in especially if they don't currently own a smart device with GPS tracking. The live in attendant, due to not wanting to give up their own phone's privacy with a app, will have to purchase a separate smart device just to clock in. Currently, the redeeming qualities of the job do not add up, and with EVV for live-ins, the community services staff will continue to diminish. Please don't let this happen to people with disabilities.

Please remove discriminatory language under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---- This is important to me because EVV for live-ins flies in the face of laws on the books to give those with disabilities rights. Not to mention, it is singling out a class of people and imposing rules and regulations that other classes of people with government jobs and those receiving government benefits do not have to adhere to. Food stamps, welfare, government employees, gov't officials, and many more - do they have to be monitored? NO!!! Community care and activities are supposed to be an option for the developmentally disabled - EVV for live-ins has more problems than anyone should have to deal with, let alone someone the is already struggling with a disability. It's time to investigate challenges to this concept, since we live in America. So to our government - we should require monitoring for all government funded programs OR not single out one group. It is the EXACT definition of DISCRIMINATION!!!! Thank you.

Remove under Item #291 - language harmful to the disabled: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Live ins work more hours than they are paid. They are making $13.88 an hour with no benefits. Live ins are available 24 hours/day, but do not receive 24 hour payment. Live ins provide a home for those they care for. Who is being ripped off here? The live ins or the state? The state doesn't even have responsibility of being employer of record. Evv tracking of live ins is a control tactic with no substantial statistics to enact it (controlling when not the employer is also borderline illegal). What if all populations were treated in such a stereotypical manner? NCIL (National Council on Independent Living) has statistics stating the fraud level in the Consumer Directed program is very low. Why is the state stereotyping everyone in the program and not paying attention to who is REALLY being ripped off?

Remove words harmful to the disabled under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Why do the disabled need 5 agencies overseeing this program? Now, you want to add Electronic VISIT Verification for live in caregivers that DON'T visit? This is oversight overkill. Please, give us a life worth living, and make the changes necessary to give us our independence back. At least give us a choice in the matter. No one wants to live like this and no one wants to go back to institutions. Thank you.

Remove under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." - This is important to me because Live ins do not visit - exempt family members from EVV. Exempt family members that live together from having to watch a clock instead of caring for their loved ones. Thank you.

Remove the language under Item #291 and help those with disabilities: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." The EVV was implemented to prevent fraud, but it does not capture the extra hours that are worked to care for the disabled by live ins. If the hours are authorized as necessary, and a live in care provider can only record those hours on a timesheet and no more , the EVV does not serve a purpose. Because live in caregivers are available 24 hours a day, the time they provide care varies from one day to the next and one hour to the next. It just does not make sense to clock-in and clock-out... Some nights I get woken twice because the client can’t breathe, so needs a breathing treatment or his water spilt and there is nver pay for overnight. Because a set number of hours are authorized, the consumer should just confirm that their care has been provided they way it is now with the portal. The EVV is not appropriate for live-in care providers. Please maintain the evv exemption for live in caregivers.

Please remove language under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--- I see EVV for live ins as an unnecessary step due to the facts that 1. the approved hours are never paid out over the approved hours with the fail-safes that payroll has in place 2. a person's life does not always run on a regimented schedule. At least 95% of live in caregivers already work over the approved hours without pay, so Medicaid is already "getting their money's worth" of the live in caregivers. EVV takes time and many individuals with disabilities require the attention and hands on. With the EVV 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.... EVV leaves everyone at risk for hacking and this is just one more possible door for individuals information/schedule/personal details to be invaded by others. Family/live-in caregivers should not be signing in and out when they live with the individual. 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. Again, they don't get paid more than the time they are authorized, but they are working more than the authorized hours unpaid. 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).

Remove wording under Item #291 here: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." 0 0 EVV for live ins is not "a life like yours" for families managing a disability. Do you needlessly 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 $13.88 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".

Remove under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." ----- Caregiving has always been a field where the kindness of another is exploited by 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.

Remove under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Consumer Direct Services are the most affordable services for the state - EVV for live ins will deplete CD svcs. That's right. The most affordable services for the state are consumer direct services. EVV for live ins will turn 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, maintain the exemption for live in caregivers, before there is no return.

Save families with disabilities a lot of grief and remove under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." We used the EVV app. for a short period. It was a nightmare. Many days the app didn't work. When it did work, it was difficult and cumbersome to use. The expectation that the live in caregiver, has to clock in and out multiple times per day to record "shifts" is ridiculous. They can only record a max of 8 hours per day. Do you have any idea how difficult it was 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 an email from payroll telling me that if there are too many corrections, 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,, 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 totaling 19 minutes, that is 1.9 minutes per day over) so payroll did not pay the caregiver for a full 8 hour shift. The system is not even smart enough to recognize minor overages. But payroll rounds 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 use the portal. It takes 5 minutes to enter a days time. EVV is causing problem that never existed and I can't imagine there is any benefit to it at all.

Please remove under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." VA needs to exempt Live in aides from having to use EVV. GPS tracking treats individuals with disabilities as 2nd Class Citizens who don't warrant protection and privacy. The APPS that aides will be required to use are full of glitches and many times do not work correctly. Live in aides are going to have to edit times all of the time Each time there has to be a manual edit, there will be a message threatening services for the disabled. EVV threatens decades of the work to create a more independent life for individuals with disabilities. The Federal mandates in the 21st Century Cures 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. There are already several forms of oversight put into place for these services. EVV is a needless burden to families and attendants.

Remove under Item #291 the words: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." ----I retired to handle our disabled child. With mental and physical disabilities and aggression, it’s all we could do (nothing else worked). 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.

Remove under Item #291 language: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." EVV needs another V for vampire (time vampire). Family caregivers have very little and very unpredictable free time as it is. Between having to diplomatically handle all the issues/problems evv will cause 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)!

Respectfully, please remove wording under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." There is no place like home. Don't take home away for many. The only option if evv does not work is a nursing home. Stop evv for live ins. Keep the live in exemption the way it is. Thank you.

Remove language under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." As a Virginia Support Coordinator I have heard nothing but difficulties with staffing and care since the inception of EVV. It would only get worse forcing this on live in caregivers. 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 for live ins.

Remove under Item #291 and help my disability REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Plese don't force ebv on my care person. It is hard to use and I can't find peopel to help me as much anymore. some one is living with me but is going to leave if ebv device must be used.

Remove this language detrimental to those with disabilities under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." - - - - - - - Federal Mandate says not to cause a burden to disabled- EVV causes a burden to live ins and the disabled. 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 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).

Remove under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." - - 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.

Remove under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." OUR son is severe disable. Autistic and Non verbal, he can be severe aggressive. He loves iPhones. The live in attendant can not use iPhone in front of him, otherwise he will have behaviors. EVV 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 or there are other problems with the system. I'm trying to understand why somebody would like to work for my son for 13.88, without any benefits and get bitten for using an iPhone? why anyone would work for a disabled individual AND EVV? You are failing us.

Remove under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."--- "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??

(Please) Remove under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." - This is important to me because with one swipe of the pen, you can damage a lot of disabled people's lives. 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.

Remove under Item #291 (please) REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change.">>>>>>> Thank you for the opportunity to comment. I have a large, nonspeaking, non-compliant, combative person on a special diet and, with a live in 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. I cannot afford to eek out those moments in order to tend to glitches, problems, mysterious issues with the EVV my live in attendant will face if EVV is forced on them. With EVV issues, my attendant will not been paid at times, and we will have to take out a personal loan to pay them out of pocket. THIS IS NAUSEATING TO THINK ABOUT, TORTURE TO THOSE OF US WHO RELY ON LIVE IN ATTENDANT CARE.

Please help the disabled and look under Item #291 and remove this wording: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." *****This is important to me, because I am a live in a caregiver. Visiting caregivers that currently use EVV say EVV is very stressful and one example they give is how the EVV GPS tracking says they are not where they are supposed to be, but they ARE where they are supposed to be. They feel they are being framed. Sometimes they say it says they are 75 miles from the client's home AND they are in the home! It will be torture to force EVV on live ins that are already burdened.

Remove under Item #291 the below harmful phrase: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."----- This is important to me because, I want to fix the health system and not break it. I have been on the Waiver for 15 years. I am ventilator dependent. I have seen a slow decline in the quality of live in nurses that have cared for me. I fear that this EVV system for live ins will continue to scare the good live in nurses away. That is unfair because once the word gets out, care recipients will lose some of the nurses they have and they will have a hard time recruiting new nurses.

Respectfully requesting removal of this paragraph under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." - The 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 EVV inaccuracies that could hold the end 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. This is abuse of the voiceless.

Please remove under Item #291------ REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."<<<< Where are the savings? EVV vendors charge dearly for their services. All agencies (DMAS, services facilitators, payroll, case managers) involved are going to have to be paid to referee all EVV flaws, down times, errors, missed clock ins, additional regulations, clock ins & outs based on real hours worked for a live in, penalization's, unreliability of thousands of personal devices, unreliability of payrolls/evv's hardware and software, etc... The worst part of all, taxpayers will end up paying more for state care when the most affordable form of care is eliminated by EVV and group homes and nursing homes are flooded.

Remove under Item #291 this language REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Live-ins don't visit. maintain exemption of live ins from evv (electronic VISIT verification). *****It is impossible to visit your own home********

Remove under Item #291 this wording: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." ....... My entire family, unfortunately, is disabled: my children, my husband, and myself. My children have live out attendants who help them daily with a variety of learning tasks and one live in attendant. The EVV app is difficult for the live outs 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 well. 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. Please don't force this on my live in attendant; they will probably leave.

Remove under Item #291 the following language: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." - - The Federal government has already exempted live-ins. Virginia exempted live ins in 2020. Live ins DO NOT VISIT and work much more than their paid hours. There really is no excuse for allowing such invasive technology to enter a live-in's life....NOT VISITS....LIVES. Please maintain live-ins' exemption from EVV!

Remove these words under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." = Four days of work that I approved for my visiting worker disappeared on the timesheet in the app. I had to go back in and answer all the questions and redo all the hours. And I get in trouble for corrections/redos. This is pure insanity; evv is not a simple clock in and out procedure. I am hoping to find a live in worker, but if EVV is forced on them, I never will.

Please, remove burdensome language under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." - 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 will be 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!

I am respectfully requesting the removal of damaging language under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change.".......... We have lost two visiting cna's due to evv. They got paid more elsewhere without having their location tracked by GPS and having to pay an additional cell phone bill for the evv app. to keep their personal phone's privacy and clock in. Now, we are afraid of losing our live in caregiver for the same reason. My family member will likely end up in a group home. That will cost Virginia taxpayers lots more. Why are you leaving the disabled hamstrung?

Please remove this language under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." - -> I hear that live in caregivers can be exempt from EVV under the CURES Act and through CMS/Fed gov't. However, Virginia is attempting not to exempt. Let me explain two situations out of many to help you better understand why live ins should be exempted. Live ins are given a small amount of paid hours, but work all the time day and night. First situation: meal preparation gets interrupted twice daily to clock in or out. Visiting caregivers currently using EVV complain about it taking a long time to get clocked in: stiff fingers on the keyboard, an app update needing to be installed before a log-in is even possible, trying to find a place in the house where there is internet, the app not working after several attempts, phone not working, phone battery not charged, etc..... So many meals will be ruined because of the time away from the stove just to to clock in or out (not to mention the danger). The second situation involves travel. We will have to pull off the interstate and highway to clock out at the paid times and then keep working unpaid (not to mention the danger). Ridiculous.

Remove the following communication under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."==================== Why risk losing the taxpayer's most affordable care solution they have.....Community Directed Care....by forcing EVV on non-visiting families who live in the home as live-in caregivers? Community Directed care saves VA taxpayers millions every year versus any other care solution available to the state. Live ins do not visit and are ever present, so what could EVV prove other than live in caregivers over time it every....single...day? When EVV for live ins erodes community directed care and folks end up in nursing homes, Va taxpayers and the disabled will suffer. For what? To prove they live in the home? This is already proven with multiple forms of documentation. Forcing EVV on live in caregivers is over kill and over reach at it's finest and it will backfire miserably.

Remove language under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."................................. I don’t have a smart phone and at my clients home where I live, there is a landline that tends to be spotty in reliability. My client is likely to end up either with a higher cost service plan or in a high cost group home cause evv is very time consuming and messes up everyone’s time and pay especially in situations where access to EVV will only be spotty... it is sad Virginia isn’t taking a stand and supporting live in care providers and people with disabilities. I don’t know why Virginia wants to shut down the lowest cost services by forcing a flawed system like EVV on live in caregivers.

Remove the language under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."XOXOXOXOXOXXOXOXOXOXOX Some people with disabilities don't have enough attendants, because $13.88/hr. and no benefits is the lowest paying healthcare job. If we don't have enough staff, the live-in is unpaid for hours worked, and you have no insurance for them. Some of us rely on live in caregivers, because we do not have any natural supports. If you erode Consumer Directed Services by enacting a difficult and flawed program such as EVV on live in caregivers, this violates our ADA rights to choose to live in the least restrictive environment possible. This could lead into disabled people being forced to live in nursing homes, which would also violate persons with disabilities ADA rights to live in the community. EVV is a nightmare scenario for live in caregivers.

The flaws of EVV that will harm live ins and those with disabilities. Please remove this language........Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change."---------------------------------------------------------------------------------------- Not a week has gone by since this EVV black box started with my visiting caregiver that they have been paid the correct amount. The app is freezing up at this very moment. This is unbelievably cruel to force on my Live in caregiver.

When all reason and financial common sense are ignored, there are ulterior motives to harm VA taxpayers and the disabled in VA. Please remove this language under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Live in caregivers save Va taxpayers millions each year over agency directed forms of care such as nursing homes. This is substantially more than any "savings" DMAS "says" it will save inflicting the disabled with EVV. Due to overhead costs, agency directed care will never match the savings live ins provide the Va taxpayer. Why introduce language to harm live ins and the disabled if they are saving taxpayer money? Even the federal government through CMS, knowing live ins specialty care, has allotted for this exception. This language forcing EVV on live ins will force more persons who receive community based care into agency directed care which costs millions more annually. It does not meet reason or financial sense! Is there an ulterior motive? Does anyone stand to profit from persons being forced into nursing homes? We don't know because the response when asked is generic and weak signaling an ulterior motive. Why subject the disabled and Va taxpayers to more cost?

Remove language very harmful to the disabled under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Our family had a WWII veteran in a nursing home. The Veteran had an active family member who traveled to visit on a weekly basis and if this can happen to a Veteran who has family coming and going I can NOT imagine what happens to those who do not. Wish we could post pictures here... both feet were very infected and had a massive ulcer. DMAS should be doing everything in its power to keep people out of these places. EVV puts people in these places. Praying for those stuck in them without anyone caring for them.

Please don't cause a live in caregiver to spend their paltry free time refereeing the myriad of issues with EVV. *****Remove under Item #291 ****REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Right now, live in caregivers follow CMS and the federal government guidelines where they are able to post their assigned hours in a portal and they have a time frame of two weeks to do this before submitting times. This time frame allows them to record time when they get a free moment (since they work around the clock, it is rare to get a free moment - even though they are only paid a portion of that time). This two week time frame also helps prevent a live in caregiver being subjected to human error, system errors, agency errors, problems with phones, down times with phones, inability to target specific times for clocking in and out due to stress of the job, etc.... If a live in has to clock in and out, then their free moments to do this will be over and above the allotted hours revealing they work more than what they are paid. This will cause them penalties and difficulties that will ensue in pay being penalized, delayed, etc.... Please don't let this happen to a valuable part of a disabled person's life. It will be chaos.

Help preserve families with disabilities ability to care in the home. ***Remember, this could be your family too: Remove under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." We are families caring for loved ones; you never know who may be next that needs the ability to stay home and care for a loved one. Could it be your family? Please, don't let this happen to your family. ***Live in caregivers do not visit. They work 'round the clock (even though their paid hours do not reflect this). They often have minds and hands full and cannot worry over a clock. It is next to impossible for a caregiver to clock in and out at their set paid hours. When they manage to clock in and out when they get a break, they will be penalized for working overtime to the point where they are paid less than their allotted hours. Not mention, there are several inherent bugs/flaws with EVV that cause a person to have to constantly be correcting, explaining, asking for help from overworked agencies, etc... **JUST TO BE PAID.

There is language that remains in the proposed budget that will impose real harm on people with disabilities and their families without any substantiated fiscal or program integrity benefit. I respectfully request that the following language be removed from Item 291 in the budget: "The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments . . . to eliminate the live-in caregiver exemption from electronic visit verification requirements . . ." The Centers for Medicare and Medicaid Services (CMS) says that live-in caregivers are not considered visitors and allows states to grant an exemption from the EVV requirement to record hours for live-in caregivers. This is important to me because my husband and older son are live-in caregivers for my younger son, Carl. Requiring caregivers to use EVV will impose real harm on people with disabilities, their families, and caregivers. Live-in caregivers do not "visit," and the use of the "visit" monitoring system does not capture the ongoing presence and involvement of the caregiver. Care is continuous, not clock-based, and using EVV misrepresents how care actually occurs. Requiring live-in caregivers to use EVV would return Virginia to a system it dispensed with for live-in caregivers in 2020. CMS recognizes that EVV is a burden and allows this exemption. Virginia has come a long way since the Department of Justice investigation, settlement, and resolution to transform the service system for people with disabilities. Removing this damaging language from the final budget is in keeping with this forward movement. Please make removing this harmful language from the final budget a priority. Thank you. Patricia Alf 8810 Dianne Place Springfield VA 22152

Respectfully requesting bad language Removal under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Keeping EVV exemption for live in caregivers is important to me, because it will be next to impossible to find an attendant. ****Their jobs are already difficult. Don't make them impossible by adding EVV. To show you what their lives are like, PLEASE READ: Here is a sample "Want Ad" for finding a live in attendant to help keep people with disabilities living in the community (with added EVV component to show the bleak future with EVV forced on live-ins) HIRING: A JOB FEATURING: no health benefits, no vacation pay, no sick time, no disability, no workers’ compensation, no retirement or 401K plan, GPS monitored time logging that tracks you which you must download on your phone, use your own data plan and minutes to support, Plan to spend your limited spare time making corrections to EVV errors and hoping you get paid right. Supported individuals must be taken out into the community and no reimbursement for your gas or transportation expenses you spend. Additionally, you need compassion and expect to be mentally and physically exhausted. Suitable Candidate must enjoy: Working in an environment with a general sense of mistrust and being treated as guilty until EVV (a broken and unreliable system) proves you innocent? Being overseen by indifferent, abusive and over-loaded caseworkers that let services expire dropping the ball on paperwork and don’t answer the phone or email? (Seriously, you can’t get anyone on the phone.)Having service facilitators not turn in paperwork in a timely manner and cause no pay for a month and a half and praying you are back paid. Working in an environment that when there is a problem- the overlords will fix the "glitch" in their software, (we hope) within 60 days. Working hard and knowing that you can't be sure when you will be paid or even if you will be paid or that the amount will be correct. Knowing that your employer will be a stressed-out family who is overwhelmed and under threats by the government to claw back funds the overlords deem invalidly paid. Being required to follow guidelines that are contained in multiple regulations without any clear instructions on how to interpret regulations.

Please help us keep our lives intact and remove the below language under Item #291: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." It is important to me that EVV not be forced on my live in attendant. Please keep the exception for EVV for live in attendants. We tried EVV for a short period and couldn't bear all the issues. My live in attendant went over my allotted time a few seconds last pay period. The last day never changed from approved to good to pay. I emailed the fiscal agent with a screen shot asking why this was happening. Never got an answer, but they changed her time and the total two weeks was a few seconds under the authorized hours. But her paycheck was also a few cents short so I don't know if they are prorating the hour or what. I never got an answer. Not good when you are trying to keep an attendant.

Remove this paragraph under Item #291 (and help the disabled) REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Keeping the live in exemption from EVV is important because my house is part of the 46% of older adults who do not have a smart phone in our house. We do not because no matter what we tried we would always get over charges for data we never used. Because we live rural, the landline we have goes down on a regular basis as well. I imagine since the Medicaid phones come with small amounts of data this would also be a problem. It isn't justified to make people purchase a $100 service and a $1000 device to access a Medicaid service. This service saves people's lives and allows them to stay in the community. It is irreprehensible that DMAS thinks it is ok to take away services. I don't understand why ACLU etc. will stand up for child sex offenders but not for the disabled. EVV for live ins is wrong. EVV for live ins is a human rights violation. Stop EVV.

Please remove the below language detrimental to many families under ITEM #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Keeping the EVV exemption for live ins is important to me because I am a live in that works with visiting caregivers who are forced to use EVV. The visiting caregivers tell me that their pay has not been right since EVV. They say there are always problems with the system or their phones, etc... I have got too much going on with my job to worry about a clock and pay issues, etc... I don't get set breaks at set times even though I am only paid for set times. I don't want to let down a family, but would you work if you didn't get paid for the hours you were there due to glitches, phone not working, app not working, etc? Would you want to waste your time correcting payment issues for a very low paying job with no benefits? I am going to have to leave this family if EVV is enacted for live ins.

Remove under Item #291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." MAINTAINING THE EVV EXEMPTION FOR LIVE INS IS IMPORTANT BECAUSE: Forcing EVV on live ins is going to get very expensive in the long run. I can see a lot of people going into nursing homes now, because no one needs this EVV stress and attendants are just going to move on. There will be nothing left but nursing homes as an option. I can see the nursing home bills versus attendant pay being astronomical in difference. None of this is making a bit of common or business sense.

Family managing a disability asks to Please remove this detrimental language in ITEM 291 REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Removing the EVV exemption for live in caregivers is very detrimental, because the Olmstead Act requires states, with some limitations, to assist people with disabilities to live at home if they would otherwise receive services funded by the state in a nursing home or institution. It is based on the Americans with Disabilities Act. Olmstead applies to individuals with developmental disabilities, intellectual disabilities, physical disabilities, traumatic brain injury (TBI), and other disabilities if a person meets the eligibility for nursing facility or other institution. EVV violates Olmstead because it is causing people to be moved out of the community.

Remove under Item #291 the below wording: REMOVE ->"NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Maintaining the EVV exemption for live in caregivers is important to me because: Our live in aide actually works way more than they even get paid . Our child only goes to school 3 hours and not consistently. (Misses frequently for dr appts or if he’s sick or there is a lot of sickness in the classroom), We work. So unless he’s in school he needs an aide all day. Our live in aide is going to leave if EVV is inacted for live ins, because they say they can't be free to work if they are worried about a clock and they are afraid of causing harm by focusing on a clock. I do not blame them. We will likely be unable to find replacement staff for the pay level, lack of benefits, no paid time off. EVV will leave left us high and dry. EVV will be the final slap in the face. Hopefully my child will get a nursing home slot when this all goes down.

PLEASE REMOVE UNDER ITEM #291 BELOW DETRIMENTAL LANGUAGE: PLEASE REMOVE: "NNNNN. The Department of Medical Assistance Services shall seek federal authority through the necessary waiver(s) and/or state plan amendments under Titles XIX and XXI of the Social Security Act to eliminate the live-in caregiver exemption from electronic visit verification requirements. The department shall promulgate emergency regulations to implement this change within 280 days or less from the enactment of this act. The department shall implement this change upon federal approval and prior to the completion of any regulatory process undertaken in order to effect such change." Maintaining the evv exemption for live in caregivers is important to me because: Guess who suffers the most from EVV? Our kids who have no one to depend on except us. Our caregivers are such a blessing they love my son and give him opportunities outside of our home. You know as well as I do that everyone needs friends and you don’t always want to be stuck with your parents or family. EVV keeps people with disabilities isolated.