Colorado Technician Training Standards Hearing - 11/28/2007

This hearing relates to Colorado State bill HB1131:

It is recommended concerned patients and advocates show up at the following meeting - I know I’ll be there. We have our foot in the door - it is now time to push.

My main concern getting into the nitty-gritty now is things will turn out to be too lax. I guess my first choice would be to see techs take two out of the three NANT tests, my second would be to take one of the certification tests (not proficiency); it looks like we are getting my third choice - techs’ choice of the three NANT tests. I was also surprised at the amount of the fee being charged - $200 bucks a year? I was thinking something larger would help get more inspections.

Anyway, here is the official announcement:
> Subject: DORA Regulatory Notice *** State Board of Health - Chapter XV
> Dialysis Treatment Clinics ***
> This is to notify you that the Department of Public Health and Environment
> has submitted proposed rules or amendments to existing rules concerning:
> Amendments to Standards for Hospitals and Health Facilities, Chapter XV,
> Dialysis Treatment Clinics.
> The proposed rules or amendments may be found at:
> The rulemaking hearing is set for Wednesday, November 28, 2007 at 10:00 am
> at Department of Public Health and Environment, Lab Bldg., 8100 Lowry
> Blvd.,
> Training Room, Denver CO 80230. For more information about the proposed
> rules or amendments, you can contact Lorraine Dixon-Jones, Policy Analyst,
> Health Facilities Division at 303-692-2889 at the Department of Public
> Health and Environment.
> We will be analyzing the proposed rules or amendments to determine if they
> may negatively impact Colorado’s small businesses, job creation or
> economic
> competitiveness. If initial research indicates possible negative impact
> in
> one or more of these areas, we will request that the entity submitting the
> proposed rules or amendments perform a cost-benefit analysis. If you want
> to provide us with feedback on the proposed rules or amendments to help us
> make that determination or to let us know how the proposed rules
> positively
> impact these areas, please email me at
> I hope you find this service and information useful.
> Bruce Harrelson
> Director
> Office of Policy, Research and Regulatory Reform

This is just a reminder about the hearing we are having on the 28th - the more the merrier. I suppose people could show up just to watch the proceedings if they want.

As for things I’ve heard so far, Joe Atkins (posts as Dialysis Joe) from Dialysis & Transplant City is worried our bill in Colorado will be too restrictive; he says this has been a problem in Ohio. He has a lot of experience in dialysis, so I’m considering what he has to say.

Also a member of our group is worried the companies will try to dilute the bill by claiming it is bad for business. I’m trying to dig into financial statements.

Anyway, wish us luck!

What exactly does DJ find to be too restrictive? We’re behind you!

Keep On Pluggin Plugger!!!

Thanks! And I’ll post what Dialysis Joe posted about this:

"Standards for dialysis technicians need to be set, in all states, but please don’t do what they have done in Ohio. It’s over complicated and is too restrictive. The entire goal of the Ohio Dialysis Technician law was to restrict the use of technicians by making the program as difficult as possible.

Requiring dialysis technicians to pass the Board of Nephrology (Nursing & Technology) hemodialysis technician certification, after one year of training, is ridiculous. Even though the organization states that it’s for technicians with a year of experience, it’s simply too much for the average person coming into the field, no matter how well they are trained.

Many people are pointing out that LPN’s take their nursing boards, after one year of training, which is true. What these individuals fail to point out is that these students are in a full time nursing curriculum for the entire year. Dialysis technicians in Ohio receive 120 hours of training and then are pushed out on the floor. You simply cannot compare the two training programs. It’s like comparring a grapefruit to a grape, in training time. Technicians in Ohio are being pushed too quickly, so quickly that most are barely getting by.

The logical thing to do is give oversite of dialysis technicians to the Colorado Department of Health and have the technicians take the NNCC hemodialysis technicia test, as it’s designed for the beginning technician. The BONENT test should be reserved as an advanced technician certification. In other words, there would be two levels of technicians. An entry level technician and then an advanced technician.

The important thing is to keep the hemodialysis technician certification set at a level that shows basic competence at the entry level. That’s reasonable. Otherwise, all you are doing is choking down access to technicians and patient’s access to care.

There are many RN’s out there who want an all RN staff, but the fact is that Medicare does not pay dialysis facilities enough money to provide an all RN staff. If an all RN staff were mandated by the powers that be, tomorrow, dialysis facilities would be closing their doors. It’s not financially practical.

So, proceed forward with caution as you folks in Colorado put this technician law together. Ignore special interests groups and think about what’s good for patients. Having competent staff is good for patients. Having no staff is bad. If you make this program too restrictive, all the dialysis facilities in Colorado will go begging for staff, and find none.

Joe Atkins, Managing Editor
Dialysis & Transplant City"

I just got back from the hearing. I would have to say it went well; I feel it went very well. We got all the provisions of the bill implemented in the state’s regulations. I had a question about some of the wording, but it was answered to my satisfaction and we mentioned the low fee being charged to implement this. The $200 fee is being charged on top of the license fee a dialysis facility is has to pay - which was $360 if I recall correctly. It still seems kind of low to me and I did point out we are 41st out of 50 states for compliance with state inspections. It sounds like if they start inspecting more here the funding for it will have to include hospitals and nursing homes - might be another bigger battle.

The three of us who testified at the state house health and human services committee also testified here - plus my state rep, John Kefalas. We mentioned our personal experiences, the financial condition of the companies, how this used to be a field of medicine where RNs gave the treatments, and the stats for this field of medicine - mortality and infections. My state rep also mentioned how some people from the dialysis companies had been helpful. Nobody from the dialysis companies testified.

I wasn’t sure what to expect, but we walked into a room at the front of the building with about a dozen people seated at the front who were with the board of health - mostly nurses and doctors from what I gathered. The room was also filled with people who I assume were either there to testify on other matters or just there to watch. At the end of our testimony the board of health members said yea or nay to the proposed regulations; we got all yeas - so we are done for now.

The surprise came after our testimony. They seemed moved by what we had to say and actually seemed to want to do more and mentioned they might be discussing this at a retreat they are going to have. I seem to recall looking into the dialysis training of RNs was one idea and there was talk of filling in gaps they might find. We got this ball rolling, hopefully it will pick up momentum.