I am Ellen Caruso, Executive Director of the Home Care Association of Colorado. Our organization represents 90 home care agencies and 10,000 nurses, therapists, aides and personal care providers who provide three million home care visits to Coloradans each year. One-third of our 60,000 home care recipients are young adults; one-third are between 60 and 80 years old; and a full one-third are over the age of 80.

Your committee has a noble cause: regulatory reform; paperwork reduction; process simplification. These are the things that are killing off our home care agencies and chasing our nurses away!

The picture of home care in Colorado in 2002 is not pretty. Since passage of the Balanced Budget Act of 1997 (BBA ’97), we have lost more than a third of our home care agencies. We now spend more money for Medicaid than for Medicare services. We have a terrible shortage of staff. We are turning patients away. Coloradans are not receiving the benefit they deserve.

Since October 1997, there has been an alarming increase in the number of regulatory requirements – both on the federal and state levels. These new regulations have significantly increased agency costs and added to home care staff workload and paperwork. Many of the regulations are unnecessary, duplicative and burdensome. Nurses are reporting they are doing 60 percent paperwork compared to 40 percent client care. Onerous paperwork is the number one reason that home care nurses are leaving home care for other settings or worse yet, for other professions!

These new regulations, one being an unnecessarily lengthy OASIS form filled out for everyone when it is only needed and used for Medicare purposes, increases agency costs and adds to our staff’s workload. All of this takes time and money away from services for the client.

I talked to a rural provider yesterday who is close to closing her doors. This is the only home health/hospice provider for an area larger than several of our East Coast states. This agency also serves as the county nursing agency.

This agency may not be able to make it financially under the new Home Health Prospective Payment System (PPS). The agency’s census is too low to pay the overhead necessary to stay in business. Even with intensive, successful fund raising, this agency is operating in the red. But the new payment methodology is just one of the problems for this and other rural home health agencies in Colorado.

The regulations – and the regulatory oversight – are so overwhelmingly complex and difficult that the nurses simply do not have time to comply with every piece of paper as well as care for patients. So, being good nurses, they take care of their patients very well. They comply with hospice requirement of being on call 24/7. Patients and families are very satisfied. Physician referrers are very satisfied. The outcomes are great! But guess who’s not satisfied? Yes – the surveyors! Sometimes a piece of paper is missing – maybe not filed – or maybe just not back from the physician’s office. Duplicate pieces of paper are required. Paper is required to satisfy old regulations and new paper is required to satisfy new regulations. "You need to do both," we are told. "You need a quality care nurse," we are told. But there is no money to hire a nurse just to do oversight and paper shuffling. This agency needs every nurse out on the road visiting patients!

In closing, the regulators (both federal and state) have not recognized the home care infrastructure -- the network of agencies – as what makes it possible for the RNs, therapists and aides to do their wonderful good work. This infrastructure is crumbling under the weight of too much paper.

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