Announcement of Public Workshop, "Examining Health Care Competition" ("Health Care Workshop") Project No. P13-1207 #00028

Submission Number:
Susan Birch
Colorado Department of Health Care Policy and Financing
Initiative Name:
Announcement of Public Workshop, "Examining Health Care Competition" ("Health Care Workshop") Project No. P13-1207
Colorado is deeply concerned about the quantity and capacity of our healthcare workforce and implications for access to care. The Department of Health Care Policy and Financing (the single state Medicaid agency, HCPF), with the participation of multiple state agencies and community partners, has led the state in successful healthcare transformation and expanded access to coverage, both through expanding Medicaid eligibility and improving access to private coverage in our state-based Exchange. To date, over 220,000 Coloradans have signed up for coverage, and so we anticipate a surge of individuals in need of primary and specialty care. However, eligibility for coverage without access to care, and an adequate workforce to provide that care, means little. We need to support and expand the healthcare workforce across all disciplines and encourage collaboration rather than competition. We need to focus on underserved and rural communities in our state with an emphasis on high demand disciplines, such as primary care and behavioral health. Scopes of practice need to be congruent with education and allow professionals to practice at the highest level commensurate with their education and training so that we have the workforce to accommodate the surge in expansion population. Particularly in harder-to-staff Rural/Frontier/Pioneer areas, we need exemptions or special considerations to grow and retain the workforce needed to serve the population. We are working with a legislatively-authorized advisory board, the Nurse-Physician Advisory Taskforce for Colorado Healthcare (NPATCH), to examine issues related to current scope of practice limitations and how those may be driving imbalances in the marketplace for health services. For example, Colorado currently has the most stringent requirements for Advance Practice Nurses (APNs) to obtain prescriptive authority. Colorado requires APNs to have 3600 hours of supervised training, almost four times higher than the requirement in any other state. Nursing professionals report that the supervision requirement is prohibitive to APNs providing care to patients. It has been reported that many APN trainees cannot get a supervisory physician willing to precept them for so many hours. As a result, Colorado is driving vital healthcare workforce members to leave the state after school and seek jobs in other states. However this is not a stand-alone issue; other factors that may be adversely impacting our APN workforce include health insurance carriers being unwilling to contract with them in their provider networks and healthcare facilities requiring prescriptive authority. Neither states nor individual organizations can examine health workforce needs or demands in a vacuum. It is imperative to take a broad-based approach that not only evaluates regulatory barriers to a more effective, efficient workforce, but also market factors. This is especially true as we predict future workforce demands. The U.S. Bureau of Labor Statistics predicts 70 percent job growth for home and personal care aides between 2010 and 2020, as our population grows older and the "Senior Tsunami" gets underway. Although in high demand, these jobs typically only offer wages at or near the minimum wage, and are thus not desirable jobs for communities interested in strong, sustainable economic growth. Identifying policy solutions for these market-driven challenges is difficult, and Colorado welcomes the FTC's examination of these issues crucial to ensuring the health of our individuals, families, and communities.