That was my initial response when I saw the letter from the Colorado Department of Public Health and Environment last week.
“Thank you for submitting your letter of intent for licensure as a home care agency. It was received on January 6, 2010. A review of your letter of intent found that your agency's name is not sufficient in order to process your application. … Please modify your agency's name that clearly reflects the services it provides.”
Let me give you a bit of background.
On December 30, Community Centered Board (CCB) Executive Directors received a letter from the State Division for Developmental Disabilities informing them that all CCBs that employ direct service providers that provide home care, or that contract with any independent contractor that has employees that provides home care, must apply to the Colorado Department of Public Health and Environment for Home Care Licensure. (By the way, in brief, “home care” essentially means non-health related care delivered at an individual’s home such as assistance with cleaning, assistance with meal preparation, etc.)
Forget that the deadline to apply was two days later, and that the State Departments were not open either of those two days. I am used to short notices and even notices that are retroactive.
Despite the facts that a) we had so little time to prepare, b) we don’t agree with this interpretation of the statute that led to this request, and c) we know that this interpretation is being debated and may change, we still went ahead and issued a letter of intent to apply for the license to keep us in good standing.
You can see the response we received to our letter above. They would like us to “modify (our) agency’s name.” We’ve been in operation for almost 45 years. The new license to do what we have been doing under contract for this duration won’t change anything except maybe our name? I’m not even sure what sort of name we should have. Or how other CCBs are faring in their application efforts. Take a look at just a few of the other names of organizations that perform CCB funtions:
Considering their names don’t explicitly state what sorts of services they provide, I expect we will be hearing from a lot of bewildered CCBs who are being asked to change their names.
And to add a little regulatory salt in the wound, “Any facility shall notify the Department of any proposed name change. If the Department determines that such change would create confusion or misrepresentation to the public … it may disapprove such name change."
Of course I am in complete agreement that it is necessary to have protections in place for consumers who receive home care (that is what the original statute that led to this whole mess was designed to do). But what does our name have to do with protection of consumers? Why should we undergo the costly and time consuming process of changing our name? How does that do anything to improve our services or the efficiency with which we deliver those services?
Believe it or not, my purpose here is not to place blame or point fingers. But surely you can’t be serious! Instead, I want to use this as an example of the lack of a coordinated effort between all parties engaged in the funding and delivery of services to individuals with developmental disabilities that has made our current system unsustainable.
If we truly want to create a system that can appropriately serve some of our most vulnerable citizens and ensure the taxpayers of our state get the best bang for their buck, we need to work together to make sure the system’s rules and regulations work in concert to reach an agreed upon goal of the best possible services. All interested parties, including the State, CCBs, provider organizations, parent groups, etc., need to part of a choreographed solution.
Otherwise, we will continue to waste valuable time and resources on dealing with issues that have nothing to do with serving individuals with intellectual and developmental disabilities.
Then again, what do I know?