Advantage CDS Agency Position Application

The Company, Advantage Home Care (includes Advantage In-Home Services, LLC , Advantage Consumer Directed Services, LLC and TPC Advantage, LLC) will obtain background checks as a consideration of employment that may include, but not limited to: employment and education verifications, social security verification, criminal history, civil history, consumer reports that include nationwide background checks, sex offender registry, highway patrol records, Department of Motor Vehicle (DMV) records, finger prints, Division of Homeland Security, public records of any kind, personal interviews and other screenings. As required by regulation, Advantage Home Care requires applicants to be registered with various state registrars prior to an employment offer being made. As allowed by law, applicants and employees are required to disclose all aliases, social security numbers and criminal convictions, findings of guilt, pleas of guilt and pleas of nolo contendere except in minor traffic violations. Applicants applying to work in the state of Illinois are not obligated to disclose sealed or expunged records of conviction or arrest, nor if they exist. All employees are required to complete an I-9 at hire and provide proof of identity. Advantage Home Care participates in E-Verify through the Division of Homeland Security. Employment is contingent upon the results of thorough background checks pursuant to federal and state regulations and Company policy. Persons found guilty of a prohibited offense as defined by regulation, regardless of adjudication or a plea of nolo contender, are not eligible for employment. Other offenses and findings may require a formal waiver to be obtained before employment will be considered as defined by regulation or make a person ineligible for employment per company policy and/or company discretion. Background checks are conducted prior to hire and throughout employment.

Job title: Advantage CDS Face to Face Visit Assessor

Reporting to: CDS Service Coordinator

Salary Range: Negotiable Based on Experience

Hours: PRN employment based on availability & need

Purpose of the position: the Face-to-Face Visit Assessor position is a field position that
performs in-home assessments on Consumer Directed Clients “Consumers”.

Key responsibilities & duties:
Review the current care plan with the client to make sure they understand what services are authorized and make sure that it meets their current needs.
Complete Electronic Face to Face Assessment in clients home using a device provided by the assessor.
Communicate client feedback/possible changes to the Advantage Service Coordinator after the assessment is complete.
Remove any outdated documents (remove old timesheets and correction forms) to ensure only current forms are being utilized
Other duties assigned by Management, as needed

Education: High school graduate or equivalent

Experience: Minimum of 2 years health care experience

Overview
It is the policy of Advantage In-Home Services, LLC, Advantage Consumer Directed Services and its affiliates (collectively referred to as the “Advantage”) to comply with all applicable federal and state laws regarding fraud, waste and abuse. Advantage acknowledges its participation as a Government Programs contractor in federal and state sponsored health care programs, including Medicaid. As a Government Programs Contractor, Advantage is subject to specific state and federal regulatory requirements related to these programs. To comply with Section 6032 of the Deficit Reduction Act of 2005, Advantage provides this policy, which includes information about its policies and procedures and the role of certain federal and state laws in preventing and detecting fraud, waste and abuse in government-sponsored health care programs. This policy applies to all employees, contractors and agents of Advantage.

Administrative Guidelines
I. Procedures for Detecting and Preventing Fraud, Waste and Abuse
Advantage maintains a Corporate Compliance Program that includes activities for the detection, prevention and investigation of fraud, waste and abuse. Advantage
is charged with maintaining a program to detect, investigate, prevent, and recover the loss of corporate, government and customer assets resulting from fraudulent and abusive actions committed by providers, members, subcontractors and employees. To notify Advantage of potential fraud and abuse issues or compliance concerns call its toll free number, 866-568-1192. Advantage acts on referrals received from internal and external sources of potential fraud and/or abuse. Additionally, the company uses other methods to identify potentially fraudulent activity such as claim data extracts.

A. Federal Laws Governing Fraud, Waste and Abuse (FWA)

i. False Claims Act; 31 U.S.C. §§ 3729 – 3733
The federal False Claims Act imposes liability on any person or entity who:
* Knowingly files a false or fraudulent claim for payments to Medicare, Medicaid, or other federally funded health care programs;
* Knowingly uses a false record or statement to obtain payment on a false or fraudulent claim from Medicare, Medicaid or other federally funded health care programs; or
* Conspires to defraud Medicare, Medicaid or other federally funded health care programs by attempting to have a false or fraudulent claim paid.
* Knowingly avoids or decreases an obligation to pay or transmit money or property to the government.

“Knowingly” means:
* Having actual knowledge that the information on the claim is false;
* Acting in deliberate ignorance of whether the claim is true or false; or
* Acting in reckless disregard of whether the claim is true or false.

A person or entity found liable under the False Claims Act is, generally, subject to civil money penalties of between $5,000 and $10,000 per claim, as adjusted by the Federal Civil Penalties Inflation Adjustment Act of 1990, and three times the amount of damages that the government sustained because of the illegal act.

Under the False Claims Act individuals with knowledge of potential violations may file suit on behalf of the government in federal court. These individuals may be entitled to a percentage of the amount recovered by the government. The False Claims Act also provides protection from retaliation and discrimination for individuals that engage in lawful acts done in furtherance of an action under the False Claims Act or in an effort to stop a violation of the False Claims Act.

ii. Program Fraud Civil Remedies Act; 31 U.S. C. §§ 3801- 3812
The Program Fraud and Civil Remedies Act (“PFCRA”) creates administrative remedies for making false claims and false statements. These penalties are separate from and in addition to any liability that may be imposed under the False Claims Act.

The PFCRA imposes liability on individuals or entities that file a claim that they know or
have reason to know:
* Is false, fictitious, or fraudulent;
* Includes or is supported by any written statement that contains false, fictitious or fraudulent information;
* Includes or is supported by a written statement that omits a material fact, which causes the statement to be false, fictitious or fraudulent, and the individual or entity submitting the statement has a duty to include the omitted fact; or
* Is for payment for property or services not provided as claimed.

A violation of this section of the PFCRA is punishable by a $5,000 civil penalty for each wrongfully filed claim and an assessment of twice the amount of any unlawful claim that has been paid.

iii. Anti-Kickback Statute
The federal anti-kickback statute prohibits Advantage, its employees, and contractors from offering or paying remuneration in exchange for the referral, recommendation or arrangement of Government Programs business. Under the anti-kickback statute remuneration is considered to be anything of value that is exchanged. Penalties that may be imposed under this statute for violations include criminal penalties, exclusion from participation in government programs and civil monetary penalties.

iv. Stark Laws
The Physician Self-Referral Act or Stark Law prohibits physicians from making referrals
for certain health services that are payable by Medicare or Medicaid to any entity with
which the physicians have a financial relationship. A financial relationship means either
an ownership interest or a compensation arrangement. The purpose of the Stark Law is
to ensure that referrals for services are made in the best interests of the patient.

v. Health Care Fraud (18 U.S.C. § 1347)
It is illegal to knowingly and willfully execute or attempt to execute a scheme to either
defraud a health care benefit program or to obtain money or property from a health care benefit program by means of false pretenses or representations. Penalties can include fines and/or imprisonment.

B. Illinois State Laws Governing Fraud, Waste and Abuse

i. Illinois False Claims Act (740 ILCS 175/1-8)
The Illinois False Claims Act is modeled after the federal False Claims Act. This Act
provides liability for knowingly presenting a false claim or record to the state or local
government or a Medicaid managed care plan for payment or approval. Violators are liable to the State for a civil penalty not less than the minimum amount and not more than the maximum amount allowed for a civil penalty for violation of the Federal False Claims Act, plus 3 times the amount of damages which the State sustains because of the act of the violator. Notwithstanding the foregoing, violators of the Act can be subject to civil penalties of $5,500 to $11,000 per claim as well as three times the amount of damages that the government sustained because of the illegal act for certain civil actions brought by a private person. As with the federal False Claims Act, individuals with knowledge of false claims may bring action on behalf of the state or the local government, are entitled to a percentage of the proceeds collected, and are protected from retaliation and discrimination.

ii. False Statements Relating to the Medicaid Program
Under Illinois state law, it is illegal for a person, firm or corporation to knowingly
obtain or attempt to obtain payment from public funds for social services, including
medical services by:
* knowingly making a false statement or representation:
* deliberately concealing a material fact; or
* a fraudulent scheme.

II. Whistleblower Protections
An individual who brings action under the Illinois False Claims Act is called a Qui tam plaintiff or whistleblower. Federal law prohibits employers from retaliating against employees who file suits on behalf of the government under the Illinois False Claims Act. Illinois law prohibits employers from retaliating against an employee for disclosing or threatening to disclose practices which violate a law and create a danger to public health or safety or which constitutes health care fraud.

C. Missouri State Laws Regarding Fraud, Abuse and Waste

i. Missouri Health Care Payment Fraud and Abuse statutes (Mo. Rev. Stat. §§ 191.900-914)
Missouri law addresses false Medicaid claims. Specifically, Missouri law prohibits:
a. Knowingly presenting a claim for payment that falsely states the health care provided was medically necessary;
b. Knowingly concealing an event affecting initial or continued payments by a medical assistance program for providing care;
c. Knowingly concealing or failing to disclose any information in order to obtain a payment from a medical assistance program to which the health care provider is not entitled or improperly increasing the amount of any such payment to which the health car provider is entitled; or
d. Knowingly making a claim for payment for health care that was provided that has a lesser value than the amount of the claim.

Criminal Penalties range from imprisonment up to seven years, restitution, and civil penalties of $5,000 to $10,000 per violation, plus triple damages measured as three times the amount of damage sustained by MOHealthNet as a result of the false claim activity. Alternatively, Missouri law authorizes the attorney general to initiate civil actions for violations of Missouri’s false claims laws and recover up to two times the amount of payments received by the person as a result of making false statements or false representations, as well as the state’s cost in pursuing the action.

Missouri law prohibits retaliation against an employee who initiates, assists in, or participates in a proceeding or court action under the Missouri Health Care Payment Fraud and Abuse statutes.

The false claims laws described in this policy create a system for preventing and
detecting fraud, waste and abuse in federal and state health care programs by providing
governmental agencies with the appropriate authority and mechanisms to investigate
and punish fraudulent activity. All Advantage employees will be educated about Fraud, Waste and Abuse, including, but not limited to, the foregoing laws and corresponding regulations.

Sources:
http://www.ilga.gov/legislation/ilcs/ilcs3.asp?ActID=2058&ChapterID=57
http://www.mmac.mo.gov/

1. Basic Definitions:
• Vendor= Advantage Consumer Directed Services
• Consumer= The Medicaid participant eligible for services. The Consumer is considered your employer.
• Attendant= You, the person who has been selected to be the caregiver/employee.
• Consumer Directed Services= Home care services authorized and paid for by Missouri Medicaid in which the consumer (client) manages/directs their own care and assumes many responsibilities noted below.

2. Consumer Responsibilities:
• Finding and selection of their own attendant
• Offering a job to their own attendant
• Training attendant to perform the tasks authorized on the consumer’s care plan
• Supervising attendant to ensure they are able to meet personal care needs of consumer
• Firing attendant if needed
• Providing supplies needed to complete tasks on care plan
• Communicating at a minimum monthly with Advantage Consumer Directed Services per state regulation.
• Ensuring attendant provides Advantage Consumer Directed Services with the appropriate information in order to be paid for services. The use of Electronic Visit Verification (EVV) is now mandatory per the state and federal governments.
• Ensuring the time submitted by the attendant does not exceed the amount authorized for. Example: Client is authorized for 200 units (50 hours) of services per month- the consumer must ensure that by the end of the month, the attendant does not turn in time over the 200 units (50 hours) authorized.
• Notifying attendant if client is not home to receive services or need to alter schedule
• Receiving care only from attendants registered and screened by the Missouri Family Care Safety Registry and the Office of Inspector General and Employee Disqualification List.
• Promptly notifying the state and /or Advantage Consumer Directed Services within 10 days of any changes in circumstances affecting your CDS plan of care and/or changes in where you live
• Prompt notification to Advantage Consumer Directed Services regarding any problems resulting from the quality of services delivered by your attendant
• Accept or select an attendant without regard to race, color, national origin, sex, age, religion, political beliefs or disability.

3. Vendor Responsibilities:
• Providing assistance in the general orientation of attendants as requested by the consumer
• Payroll and Accounting functions on behalf of the consumer including collecting EVV records for services rendered and verifying their accuracy, paying the attendant, ensuring all taxes are paid and filing claims for Medicaid reimbursement, preparing annual W2s, etc.
• Making contact with each consumer monthly in order to provide ongoing monitoring of services, ensuring the plan of care is sufficient and being followed and other services as needed to live independently
• Processing of consumers’ and/or attendants’ inquiries and problems
• Public information, outreach and education activities to ensure that persons with disabilities are informed of the services available and have maximum opportunity for participation
• Maintain confidentiality of consumer’s records, including eligibility information from DSDS, according to federal and state laws and regulations
• Ensure the consumer has an emergency and/or back up plan
• Monitor utilization of units by the consumer at least monthly
• Providers must maintain a list of eligible attendants
• Ensure that all attendants are screened and employable according to the Family Care Safety Registry (FCSR), the Office of Inspector General (OIG) and the Employee Disqualification List (EDL).
• Ensure the attendant is not the consumer’s spouse
• Notify the attendant of their responsibility to comply with applicable state laws and regulations regarding reports of abuse and neglect.
• Maintaining confidential consumer and attendant files that are available for inspection
• Submission of quarterly and yearly reports to Medicaid Audit and Compliance.
• Advantage Consumer Directed Services will not discriminate regarding employment on the basis of race, color, national origin, age, sex, handicap/disability, and religious beliefs.

4. Attendant Responsibilities:
• Provide personal care tasks to the consumer
• Follow the Care Plan for the consumer
• Provide “hands on” assistance with physical tasks that benefit the consumer (no time is allocated for stand-by assistance like prompting or cueing). No time can be allotted for respite care or time spent waiting for a consumer at a doctor’s office or any other appointment
• Use electronic visit verification to record time in, time out and tasks completed during shift.
• Provide open and accurate communication to Advantage
• Agree to only provide services to the consumer and not the family or anyone else living with the consumer
• Agree to not commit any acts of fraud, waste or abuse.
• Agree that as a mandated reporter, a personal care attendant is required to report all reasonable suspicion or observation of abuse, neglect, exploitation, possible imminent physical harm or bullying that would require protective services, etc. (MO Adult Abuse and Neglect Hotline: 1-800-392-0210)
• Must meet the other initial requirements listed below.

5. Attendant Qualifications:
• Be at least eighteen (18) years of age
• Be able to meet the physical and mental demands required to perform specific tasks required to meet your care plan needs
• Agree to maintain confidentiality
• Be emotionally mature and dependable
• Be able to handle emergency type situations
• Not be the consumer’s spouse
• Be registered with and screened by the Family Care Safety Registry (FCSR), Employee Disqualification List (EDL) and Office of Inspector General (OIG). Advantage Consumer Directed Services will run these background checks to ensure the person you are trying to hire is eligible.

6. Required Background Checks:
• Advantage will run the necessary background checks to ensure a person is eligible to work as an attendant. This includes being screened by the Family Care Safety Registry, Office of Inspector General and Employee Disqualifying List. If an attendant has lived outside of Missouri for the past 5 consecutive years, a nationwide background screening will also be conducted. If there is a finding on one of the background checks, we will determine if the crime is listed on the disqualifying crimes list per the Missouri Medicaid Audit and Compliance: https://mmac.mo.gov/wp-content/uploads/sites/11/2019/06/Disqaulifying-Factors-FCSR.pdf
• If the crime is listed on the disqualifying list, the person will need to apply for a Good Cause Waiver if they have not previously obtained a Good Cause Waiver. They MUST obtain this waiver before they can be hired.
• At times, there may be a finding that is not severe enough to be on the official disqualifying crimes list but could be something that either a consumer or the vendor is not comfortable with. Both the consumer and Advantage Consumer Directed Services (vendor) holds the right to not enter into an employment contract with someone that has such a criminal record.
• Advantage Consumer Directed Services holds the right to run background checks on attendants routinely throughout their active employment status. At any time in their employment, if it is discovered that an attendant has a recent finding that is on the disqualifying list, the consumer and attendant will be notified that services must stop immediately. The attendant cannot resume services until a good cause waiver is obtained. We do hold the right to end or suspend our employment contract with the attendant for any finding discovered that we are uncomfortable with. You will be notified promptly when and if this does need to occur.
• Advantage will complete an I-9 on all attendants and check the E-Verify to ensure they are legally able to work in the United States. You are required to show proof of a photo ID and social security card.

7. Tasks that may be performed during CDS Services: The consumer will have a care plan that has been tailored to meet their individual needs. The care plan is NOT written by Advantage Consumer Directed Services. At a minimum, the tasks on the care plan must be performed. Additional tasks may be performed but the time spent cannot exceed the time authorized on the care plan.
• CDS may include the following tasks:
o Bathing; including shampooing hair
o Dressing/grooming; includes dressing/undressing, combing hair, nail care, oral hygiene and denture care and shaving
o Ostomy/catheter hygiene
o Bowel and Bladder routine
o Assistance with toileting
o Use of transfer devices/assistance with mobility issues/prostheses
o Passive Range of Motion
o Manual assistance with medications (prompting while assisting, opening mediplanner, handing a glass of water, steadying the glass of water)
o Turning and positioning
o Treatments
o Cleaning and maintenance of equipment
o Clean bath
o Make Bed
o Change linens
o Clean floors
o Tidy and dust
o Laundry (home or off-site)
o Trash
o Read/write essential correspondence
o Meal prep and/or assistance with eating
o Wash dishes
o Clean Kitchen
o Essential transportation- Essential shopping/errands, school or employment. (See transportation questions manual for further details. )

8. Services that are NOT included as a part of the CDS program:
• Tasks that would primarily benefit people other than the client (others that reside in the home)
• Tasks that others living in the household may reasonably be expected to do or share, unless the task is above and beyond typical activities that would be provided for a household member without a disability.
• No time can be provided for stand by assistance, prompting or cueing.
• No time can be provided for respite care or time spent waiting for you at a Doctor’s visit or other appointment
• Tasks that must be performed by a licensed professional (example: nurse, doctor, therapies, etc)

9. Care Plan Training
• Missouri Medicaid has made a Care Plan that has been tailored to meet the individual needs of your consumer. It is crucial that this care plan is always followed. If changes need to be made, your consumer should call the state.
• The Care Plan consists of:
o Start date and end date
o The vendor agency chosen to provide services
o The monthly units authorized for (In order to determine how many hours this equates to follow the formula:
i. Total units – transportation units= Units of personal care
ii. Units of personal care / 4 = Total hours of personal care each month
iii. Transportation units / 4= Total transportation time each month
o Tasks that should be performed by personal care attendant during each shift
iv. You will notice that there is a time frame associated with each task. This is the time that you should spend doing each task. You must ensure that if you work a certain amount of hours, that you also record enough tasks to warrant those hours. Example: The attendant works 2 hrs so they need 2 hours worth of tasks marked for the day. This is extremely important!

10. Scheduling:
• It is the consumer’s decision on what time of day services are rendered. We do ask that you provide Advantage information on when transportation will be provided each week, as the information is needed for our EVV system.
• Remember, you have a care plan to follow so the schedule needs to be at a time of day that allows the care plan tasks to be done. For example, if the consumer goes to bed at 9pm then it does not make sense for you to come at 10pm.
• It is generally best if the consumer determines ahead of time, what their typical schedule will look like each month. This helps you follow the care plan and also helps to ensure all hours are used but that you don’t go over at the end of the month.

11. Electronic Visit Verification (EVV):
• EVV is short for Electronic Visit Verification which is a timekeeping system that requires you to electronically verify you are present and working by means of calling from the consumer’s land line or using a smart phone based app. It is required by Federal and State law for all Medicaid funded personal care services. EVV eliminates the need for paper timesheets and allows the attendant to provide the same information, just in electronic format at the exact time the services are being rendered instead of turning in timesheets days later.
• In order to get paid for your time working, you must submit clear and accurate information to Advantage that proves you did provide services to your consumer.
• The information that must be recorded is your consumers name, your name, the tasks that were performed, date, clock in time, clock out time and location of where service delivery begins and ends (GPS).
• Rules for EVV: Your goal as a CDS attendant is to successfully use the EVV system 100% of the time without the need for manual edits of your electronic records.
o If you have any problem at all using EVV, it is your responsibility to promptly call Advantage’s EVV Call Center to get assistance.
o You must use EVV at the start and end of every shift in the consumer’s home with the consumer present.
o Effective 3/27/22 all visits that require a daily correction form / paper timesheet will have their pay rate (for that specific shift) reduced to the branch base pay rate.
o Effective 3/27/22 all shifts that come through the EVV system cleanly (no correction form needed) will be paid a special “EVV Incentive” rate.
o If the shift information is not complete or accurate in the EVV system, you are required to submit a signed Daily EVV Correction Form to the office to verify the details of your shift. This must be submitted within 48 hours of the worked shift. If this is not submitted in time, your pay may be delayed and pushed back to the next payroll period. (We will not accept the weekly timesheet to be used)
o When clocking out, you are required to enter task codes that correspond with the services rendered. It is important that the care plan is being followed and that enough tasks are being performed for the time spent clocked in. For example: If you are clocked in for two hours, you should enter two hours worth of tasks. You cannot clock in for two hours but only enter thirty minutes’ worth of tasks. In this scenario, initially you will only be paid for the time spent providing tasks to your consumer (30 min). If you feel there has been a mistake made and need to submit additional tasks to reach the full clock in time (2 hours), you will have to submit a signed Daily EVV Correction Form listing the additional completed tasks in order to be paid for the full shift. If not completed within 48 hours of the shift, it will be considered late and will be processed during the next payroll cycle.
o We will not contact you regarding missing or incomplete EVV records. YOU are required to call the EVV call center if you have any problems using the electronic system. These calls must be made while you are the home, when the issue occurs. Any changes to an electronic visit will require the completion of a Daily EVV Correction Form which must be submitted to the office within 48 hours of your scheduled shift in order to avoid payroll delays. The Daily EVV Correction form must be completed accurately and must be signed by the client in order for the change to be submitted to payroll. Advantage will not process missing or incomplete payroll records for any reason whatsoever. Failure to submit accurate payroll records could result in delays to when you receive your check.

• Adverse Actions:
o The state of MO is closely monitoring EVV records for every provider. They can view all records in live time and will know when manual changes to electronic records occur. As a result, the manual editing of visits must be kept to an absolute minimum. If you are found to be repeatedly out of compliance with EVV rules and using the Daily EVV Correction Form too often, your direct deposit may be turned off and your pay will be delayed. In extreme cases, Advantage may have to suspend services until all parties agree to be complaint.
o If the Daily Correction Form is not turned into the office within 48 hours of the shift, it will be considered late and will be processed during the next payroll cycle. This means it would be paid out 1 week later than it would if it were on time. Refer to payroll calendar for payroll dates.
o After adequate training has been provided to you, if you are still having to use Daily EVV Correction Forms each and every week, you will be notified that your direct deposit will be turned off & you will have to come into the office to pick up your paycheck. We may also elect to put your paycheck in the mail on your pay date. Your direct deposit will be turned back on once you demonstrate for 2 weeks in a row 100% EVV compliance (i.e you can use the system without the needing a Daily EVV Correction Form).
o In extreme cases, if all parties are still out of compliance and all efforts have been exhausted to help you, Advantage may have to terminate the attendant employee contract.

12. Client/Consumer EVV FOB Policy:
• Regulation:
o State and Federal regulation requires all Medicaid home care recipients to allow the use Electronic Visit Verification (EVV) in their home. EVV can be administered through a smart phone based APP, through a landline telephone in the client’s home or through the use of a validator box that is secured in the client’s home. The validator box is called a FOB. The FOB must be secured in the home so it cannot be easily removed. The FOB must be in a location that is easily accessible to the caregiver to use at the start and end of their shift, as they are required to use it to clock in and out.

• Responsibilities:
o In situations that require the use of a FOB, Advantage Home Care will provide the FOB to the client along with examples of how to secure it in their home. It is the responsibility of the client to ensure that the FOB is secured in the home and that it stays in the home at all times. If at any time, the client discovers that the FOB is missing, it is the client’s responsibility to notify the office immediately. Upon termination of services, we ask that the FOB be returned to the office
o Employee/Attendant Responsibility: If it has been decided that you are required to use a FOB in order to clock in and out, it is your responsibility to notify the office if you see that the policy requirements are not being followed by the client. In no circumstances are you allowed to remove the FOB from the client’s home unless the branch office has instructed you to retrieve the FOB and bring it back to the office. If it is discovered that you have tampered with or used the FOB outside of the client’s home in order to clock in and out; you could face termination of your attendant employment contract and be hotlined to the Medicaid Fraud Unit.

13. Post Merger Integration Strategy:
• Advantage Home Care acquires many attendants by means of acquisition. Advantage Home Care will initiate a Post Merger Integration Strategy (PMIS). This will grant the new attendant a short grace period after the sale to allow them time to comprehend and transition to following Advantage policies and procedures. During this transition time, it is the mission of Advantage Home Care to provide the field employee with feedback, re-education, extra training and guidance in order for them to find success in their role as Attendant before all policies and procedures are strictly enforced. Please note, this grace period does NOT mean that we can allow for unethical, fraudulent, or dangerous behavior. There is no grace period for actions or behaviors that fall under those categories. The grace period is directly related to payroll functions and procedures.

14. Payroll Process and schedule:
• Each payroll week is Sunday through Saturday
• Upon hire, CDS attendants will be provided with a pay schedule that clearly outlines when each week will get paid out. At the start of the new year, it is the attendant’s responsibility to call the office and ask for a new payroll schedule.
• Advantage only authorizes attendants to submit time up to the total hours authorized on the consumer’s care plan. For example: if the care plan allows for 80 hrs per month, the attendant can only submit and be paid for 80 hours. Any additional hours submitted that exceed the total authorized hours on the care plan are not authorized and will not be paid.


15. Fraud of the Program: Below is a list of situations or circumstances that would be considered fraud and should be avoided.
• Your consumer must be present in order to receive services. Example: Your consumer cannot be at the movies or visiting with a neighbor while you are clocked in at their home.
• Your consumer cannot be receiving care at a facility or hospital during CDS hours. Example: They are admitted to the hospital for 2 days but you go to their house each day to walk the dog and tidy up. Or, you come to the hospital to visit each day and decide to clock in while you are visiting because you help while you are there. Both of these situations would be considered fraud. Services can start back up once your consumer is discharged and back at their home.
• Your consumer cannot clock you in and out because you cannot make it one day. Example: you are out sick on Tuesday but you really need the money so you have your consumer clock you in and out even though you did not work. This would be considered fraud.
• You cannot have your consumer clock you out later if you have to leave early. This would be considered fraud.
• You cannot submit fraudulent time for services not delivered. Example: You are submitting time for working but have not been actually providing you any services. If your consumer makes a suggestion like this, you should not turn a blind eye to this behavior or you are also committing a crime. Always call Advantage or the Missouri Fraud Hotline: 573-751-3285

16. Consumer Rights:
• Receive services without regard to race, color, national origin, sex, age, religion, political beliefs, or disability.
• To be treated with respect and dignity
• Have all personal and medical information kept confidential
• Have direction over services provided as long as care plan is being followed.
• Know the providers established grievance procedure and how to make a complaint about the service and receive cooperation to reach a resolution without fear of retribution
• Hearing Rights: (per 19 CSR 15-8.500 Hearing Rights)
o When a consumer is determined ineligible for consumer-directed services (CDS) or when a dispute arises concerning the provision of CDS, after the preparation of the CDS plan (plan of care), or termination of CDS, the consumer may request in writing a hearing with the Dept of Social Services (DSS).
o A consumer may request a hearing by contacting Department of Health and Senior Services (DHSS) in writing within 90 days of denial or eligibility, denial of financial assistance, the determination of financial assistance, discontinuation, suspension or reduction of CDS.
o If the consumer appeals in writing within 10 days of the mailing of the notice regarding denial, suspension, reduction or termination of CDS, DHSS will not suspend, reduce or terminate services provided to a consumer under an existing plan of care pending a decision from a hearing, unless the consumer requests in writing that services be suspended, reduced or terminated.

17. Consumers are not allowed to:
• Threaten or abuse or allow other members of your household (or guests) to threaten or abuse provider staff. This will result in your services being terminated
• Expect care to be provided to your pets, friends or visitors. This is not allowed under the CDS program.
• Allow services to be provided in your home when you are not home.
• Engage in activities that would be considered fraud of the program, for example: submitting time for payment for services that were not actually provided. This could result in your services being terminated.

18. Essential Transportation
• Some CDS consumers will be authorized essential transportation on their Care Plans. This includes all essential shopping/errands (whether or not the participant is with the CDS attendant), school and employment. For the participant to be eligible for transportation assistance there must also be an identified need for personal care assistance, even if that need is met by supports other than CDS.
• CDS Transportation does NOT include transporting to medical appointments when that appointment is covered under the NON-Emergency Medical Transportation (NEMT) program. To determine if the medical appointment is covered by NEMT, contact the NEMT provider at 1-866-269-5927.
• There are many questions that arise when determining if a situation would be authorized under Essential Transportation. Please feel free to ask a vendor representative or refer to the Policy Clarification Questions and Answers located at: https://health.mo.gov/seniors/hcbs/pdf/pcq.pdf.

19. Signatures:
• There may be times that a consumer and/or attendant signature is required to verify information. When this occurs, we ask that only full names be used. We prefer no initials of any kind be used in order to validate the person’s identity. (Because of physical restrictions, if the consumer is physically unable to sign their full name, we do allow the consumer to make their “mark” but another responsible person in the home must sign their name (not the consumer’s name) after the mark as the witness. If no consumer “mark” can be made, the responsible person/witness can sign their name as long as the consumer is present to authorize the signature.)

20. Liability for injuries, illness and damage
• The attendant is the employee of the consumer and is never considered an employee of the vendor, Advantage Consumer Directed Services. With that being said, Advantage Consumer Directed Services is not liable for any illness or injuries sustained by the attendant or consumer. Advantage Consumer Directed Services also has no liability towards damages done to possessions of the attendant or consumer.

21. Abuse & Neglect/Exploitation/Misappropriation/Falsification of Services
• Advantage Consumer Directed Services strictly prohibits abuse or neglect towards consumers.
• All attendants will be trained upon hire by Advantage Consumer Directed Services to recognize abuse and neglect. As an attendant, you are considered a mandated reporter and must report to the department and/or the vendor immediately any alleged or suspected abuse of a consumer. Failure to report the suspected abuse or neglect could result in termination of employment contract, criminal prosecution, or both.
• The 5 definitions of abuse and neglect are: Neglect, Misuse of Funds / Property, Physical Abuse, Sexual Abuse and Verbal Abuse.
• Procedure for Identification and Reporting:
o Any attendant who has cause to believe that a consumer has been subjected to abuse, neglect or any fraudulent activity should report it immediately to the vendor and the Elder Abuse Hotline (1-800-392-0210) or MMAC Fraud Hotline (573-751-3285)/mmac.reportfraud@dss.mo.gov or to the Child/Abuse Hotline (1-800-392-3738).
o All reports are confidential.
• It is the policy of the Vendor to take the appropriate steps to prevent the occurrence of abuse, neglect, exploitation and misappropriation of Consumer funds, including falsification of service delivery documents. The Vendor will ensure that all alleged violations of any of the before mentioned are reported immediately to the Elder Abuse Hotline (1-800-392-0210) or MMAC Fraud Hotline (573-751-3285)/mmac.reportfraud@dss.mo.gov or to the Child/Abuse Hotline (1-800-392-3738).
• As stated in a previous section, EVV records need to be a true and accurate representation of the services that were rendered. Those records become a part of the billing process, part of the consumer chart and a legal document. Any falsification of records will not be tolerated by the Vendor and will be hot lined immediately.
• Please refer to the additional Abuse and Neglect training as well as the False Claims Act training provided to you as a part of your Attendant Orientation.

22. HIPAA and Client Confidentiality Policy:
• It is the policy of Advantage Consumer Directed Services and expected that all consumer medical information is kept strictly confidential. This means that consumer identifying information is not shared with anyone, including family members. This includes consumer care plan information and any other documents provided regarding the consumer. Care Plans and other forms provided to attendants from Advantage Consumer Directed Services should be kept in a private and secure location.
• Any breech in this policy is subject to termination of the employee contract by the vendor and possible legal actions for violations of applicable regulations and laws.
• Refer to additional HIPAA training manual provided to you during your Attendant Orientation for more information.

23. Drug Free Workplace:
• It is expected that all parties maintain a drug free environment in which services are to be delivered. Services can be suspended or terminated by any party if another member should be in breach of this policy.

24. Consumer Emergency and Backup Plan:
• Each Consumer is required to have an emergency and backup plan in case of emergencies. It is your responsibility to make yourself familiar with this plan.

25. Preparing for Emergencies:
As an attendant you are required to be able to handle emergency type situations. When there is a medical emergency it is recommended that you call 911 immediately. There are ways to prepare for common emergencies prior to them happening. Many resources can be found on the DHSS website here: https://health.mo.gov/emergencies/readyin3/

26. Vendor Text/Email Notifications
• Advantage Consumer Directed Services may send out text/e-mail notifications to consumers or attendants to pass on information. If you wish to not receive any updates from the agency via text or e-mail, you have the ability to opt out/unsubscribe at any time.

27. Employee Reference Requests:
• As a vendor for the MO Medicaid CDS program, we are not required to check employment references upon hire for attendants. However, if a consumer would prefer that references are obtained we would be happy to either pass on the information to the consumer so they can call on the reference or we can obtain the reference ourselves upon Consumer request.

28. Vendor Oversight:
• The Attendant and Consumer must keep open communication with the VENDOR regarding scheduled hours and when services are not able to be delivered. The VENDOR will also conduct mandatory monthly telephone check in calls as well as an annual face to face visit in order to monitor services being delivered.

29. Grievance Policy and Procedures:
• It is the policy of this Vendor to provide all attendants and those seeking services with a copy of the Grievance Policy and an opportunity to file a grievance. If you choose to file a grievance, be assured that no adverse repercussions will occur to you in any future interaction with this vendor.
• You can file a grievance in three ways. You will receive a response in a timely manner.
o Call the Your Voice Matters Reporting Hotline: 314-530-7979.
o Email: reporting@advantagehomecare.com
o Writing a letter to the Director of Advantage Home Care at 11796 Westline Industrial Dr. St. Louis, MO 63146
30. Vendor Mission and Values
• Mission Statement: We help people remain safe, healthy and independent in the comfort of their own homes by expanding our customers access to choice.
• Vision Statement: Advantage’s culture is driven by exceptionalism, integrity & innovation. We are obsessed with providing exceptional customer service & promote transparency, and collaboration in all that we do. We pride ourselves on communication & measure success by the value we create in the communities we serve.
• Core Values:
o Customer Service: Provide fanatical customer services in all that we do.
o Integrity: Always do the right thing, even when no one is looking.
o Respect: Always treat clients, employees, coworkers & referral sources with dignity & respect.
o Innovation: Promote a culture of innovation and continuous improvement throughout our organization.
o Culture: Foster a family friendly culture that others want to be a part of by being professional, happy and fun.
o Exceptionalism: Show our passion for what we do by always striving to be the best that we can be.
o Communication: Promote open, honest, clear and concise communication at all times
o Community: Remain active participants in the communities we serve & try to help others anytime we can.

31. COVID-19 Policy
• You can view the agencies full COVID-19 policies and procedures on the website at: https://www.advantagehomecare.com/covid-19/
• We suggest that all attendants should cease providing services to their client if they are experiencing any symptoms related to a communicable disease including the novel coronavirus.
• We suggest that an attendant should contact the office upon onset of symptoms to make us aware so we can take appropriate action.
• During the coronavirus pandemic, it is suggested that all attendants ask their consumer a series of questions prior to the start of their shift. If the consumer answers “yes” to any other questions (besides the question relating to social distancing), we suggest they cancel their shift and contact the office immediately for guidance.
• Below is a list of the questions. PRIOR to making direct contact with the consumer, attendants should identify consumers at risk for having COVID-19 infection (This can be done over the phone before arrival or upon arrival but while maintaining 6ft of distance from the client). They should ask the consumer the following questions before providing any type of services:
o Have you traveled within the USA or internationally in the last 14 days?
o Have you had signs of a respiratory infection in the last 14 days such as a fever, cough and/or sore throat?
o Has anyone you live with had signs of a respiratory infection in the last 14 days such as a fever, cough and/or sore throat?
o Have you had contact with anyone who has been diagnosed with, or screened for COVID- 19?
o Are you practicing social distancing including staying at home and not allowing visitors?


Attendant Acknowledgement of Training and Vendor Policies Agreement

The Following Topics were reviewed during attendant orientation and training:
1. Basic Definitions
2. Consumer Responsibilities
3. Vendor Responsibilities
4. Attendant Responsibilities
5. Attendant Qualifications
6. Required Background Checks
7. Tasks that can be performed
8. Services that are not included with CDS
9. Care Plan training
10. Scheduling
11. Electronic Visit Verification (EVV) Policy and Rules
12. Client/Consumer EVV FOB Policy
13. Post Merger Integration Strategy
14. Payroll Process, schedule and paycheck information
15. Fraud of the Program including examples of fraud
16. Consumer Rights
17. Consumer prohibited activities
18. Essential Transportation
19. Signatures
20. Liability for injuries, illness and damages
21. Abuse, Neglect, Exploitation, Misappropriation and Falsification of Services
22. HIPAA and Confidentiality Policy
23. Drug Free workplace expectations
24. Consumer Emergency and Backup Plan
25. Preparing for Emergencies
26. Vendor text and email notifications
27. Employee Reference requests
28. Vendor oversight including monthly calls and annual face to face visits
29. Grievance Policy and Procedures
30. Vendor Mission and values
31. COVID-19 Policy
32. False Claims Act
33. Agency Contact Information

It is important to be ready for emergencies. There are many resources from the state that help you and your consumer prepare for an emergency. They can be found here: https://health.mo.gov/emergencies/readyin3/