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that effective programs of utilization review are adopted and practiced. The Association believes that, if such Federal standards are adopted, quality of care can be ensured. Without such uniform standards, it is possible that arbitrary certification procedures could be adopted in some areas that would discriminate against home care in general, and possibily discourage the establishment of new agencies in areas of need.

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Legislative Committee
National Association of
Home Health Agencies
1715 E. Burnside Street
Portland, Oregon 97214
(503) 233-5441

NATIONAL ASSOCIATION OF
HOME HEALTH AGENCIES

1975

President

Hugh Rohrer, M.D.

Director of Health

Peoria Health Department

Peoria, Illinois

Vice President

Neal Colby, Jr., M.S.W.,

Administrator, Home Health Care

Catholic Family & Community Services
Kansas City, Missouri

Secretary

Dorothy E. Gerrard, R.N.

Executive Director

Visiting Nurse Service, Inc.

Phoenix, Arizona

Treasurer

J.T. Gilbert, R.P.T., President

Central Miss. Home Health Agency

Jackson, Mississippi

Executive Director

Margaret D. Lewis

Denver Visiting Nurse Service

Denver, Colorado

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Mr. ROSTENKOWSKI. Thank you, Mr. Trautman.

I want to take this opportunity to welcome certainly a very famous and popular Member of Congress, a gentleman who has done a great deal in health care, our colleague from the powerful Rules Committee, Senator Claude Pepper. It is always nice to visit with you.

Welcome, Senator.

Mr. PEPPER. Thank you very much, Mr. Chairman.

Mr. ROSTENKOWSKI. Mrs. Moore?

STATEMENT OF FLORENCE M. MOORE

Mrs. MOORE. Thank you.

I am Mrs. Florence Moore. I present this testimony in my capacity as executive director of the National Council for Homemaker-Home Health Aide Services, a national nonprofit 501 (c) (3) membership organization with offices at 67 Irving Place in New York City.

Since you have agreed to publish our statement, I would like to just speak to portions of the statement.

There have been a number of actions recently on the Federal scene which focus on home health services. Some of these actions are in the form of laws such as Public Law 94-64; some are in the form of proposed legislation such as the Koch and Moss National Home Health Care bills; and some are in the form of proposed regulations, such as those issued in the Federal Register during 1975 on May 14, June 9, July 9, and August 21. The national council wishes to comment on the overall impact that these various plans would have on home health care, including homemaker-home health aide services, if they are implemented.

Expansion of home health services and especially homemaker-home health aide service would be one outcome of these various developments. This is a goal long sought by the national council and its members as well as by colleague organizations, some of whom are represented here on this panel this afternoon, to counter the current well-documented imbalance between institutional and in-home health services.

For example, implementation of the home health section of title VI, section 602 of Public Law 94-63 will contribute substantially to achievement of this goal in the provision of startup or expansion funds for some new services and for training personnel, both professional and paraprofessional. We urge that authorized funds be appropriated for at least this section of Public Law 94-63 so that its potential for expansion of the services will become a reality in this fiscal year.

Expansion of homemaker-home health aide service is a goal also in the Koch-Moss National Home Health Care bills. It is clearly a goal, too, in the proposed regulations issued in the Federal Register on August 21, 1975 by the Medical Services Administration, Social and Rehabilitation Service, DHEW. The health systems agencies being developed under Public Law 93-641 will have a singular opportunity to call a halt to the overutilization of one aspect as the health services continue at the expense of others since these planning organizations will have control of some Federal funds coming into their areas.

The overall effect of actions such as these, at least for the provision of in-home services, would appear to be an incremental approach to

ward a national health care system. Therefore, the consequences of these developments, already vitally important, take on added meaning. The national council's overriding concern now about the future of homemaker-home health aide service is that the same attention is not being given to development of standards and to expansion of the monitoring systems as is being given to the expansion of the service. It is vital that service provided to vulnerable persons in their own homes be provided with the utmost regard for the safeguards which will protect them, based on a carefully developed set of national standards.

It is imperative that there be monitoring of each agency by an objective outside body to assure that the services people receive are needed, are appropriate to the need, and are provided effectively, efficiently, and humanely. Key standards include: assessment of need and establishing a plan of care by a qualified professional person so that service is tailored appropriately in each situation; careful selection of homemaker-home health aids; training for and supervision of the homemakers appropriate to the responsibilities to which they are assigned.

Those who write legislation and those who promulgate regulations for this field must take steps now to prevent the kind of abuses found in the nursing home field from developing in the in-home services field. Those who are served at home are equally vulnerable while much less visible than those cared for in institutions.

The national council recommends the following actions:

One: That Federal funds be made available immediately to the States to assist them in strengthening their units responsible for the certification-monitoring-process under medicare and medicaid. Each State should be required to submit to and have approved by the Federal Government its plan for the use of these funds for monitoring the quality of home health services. In addition, Federal training programs should be established and conducted for the personnel undertaking this certification process as the Federal Government is doing. now for similar personnel certifying nursing homes.

Two: That quality assurance procedures, utilization review, medical review, PSRO activities and fiscal accountability not be limited to institutions, but also concern themselves with home health services. Three: That the Federal Government utilize the quality assurance programs, namely, standards, of the national voluntary, nonprofit sector to complement the public role in monitoring home health care. There is a precedent for this in the use the Federal Government makes of the Joint Commission on the Accreditation of Hospitals.

This principle should be extended to the standard-setting and monitoring programs of national voluntary organizations, such as that of the National Council for Homemaker-Home Health Aide Services for agencies which provide any aspect of homemaker-home health aide. service. It will require the voluntary and the public sector working together to assure quality service in this rapidly expanding field.

The national council's new national approval program has already approved close to 100 agencies providing homemaker-home health aide services and a like number are in process. We urge that approval by this national organization serve in lieu of State certification of

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