As a leader in Colorado’s home care community, we have always believed that our industry is only as strong as its integrity. Recent developments from the Department of Health Care Policy and Financing (HCPF) regarding the proposed Provider Accountability Rule (8.7420) signal that the Wild West era of home care marketing is coming to a close.
For families and caregivers, this is a moment of profound significance. These proposed rules are designed to protect you from predatory behaviors that have, for too long, gone unchecked in our community.
Moving Past the Wild West of Marketing
We have all seen the shift in how home care is discussed online. From unsolicited social media DMs to Facebook group messages promising guaranteed pay without context, the noise can be overwhelming. The proposed rules specifically identify and prohibit practices such as providing structured responses to families or influencing how limitations are described during assessments to artificially secure more hours.
This practice is deeply concerning. When agencies influence how limitations are presented in a way intended to inflate care needs, they aren’t just bending the rules. They are jeopardizing the long-term stability of the caregiver’s career and harming the overall solvency of the very programs that sustain us. These programs were designed to alleviate the nursing shortage and provide a sustainable path for loved ones to stay at home. Harming the system’s integrity eventually leads to the very draconian cuts we are currently seeing.
Wage Leadership vs. Member Inducements
The proposed rule specifically targets inducements—the offering of gift cards, cash, or transfer bonuses to influence a family’s choice of agency. At Caregivers First Choice (CFC), we take a different approach. We don’t believe in begging you to join our agency with a one-time prize.
Instead, we focus on Wage Leadership and Transparency. We believe in rewarding experience with higher hourly wages and offering a career path based on professional expertise. While some may argue that referral or transfer bonuses are just employment bonuses, the state is making it clear. Any thing of value used to coerce a member’s choice is a violation of the trust we hold as providers.
Audit-Proofing as a Professional Standard
The proposed rule introduces significant administrative hurdles, including a requirement to track and maintain six years of documentation for all marketing and communication. For some, this will feel like an unnecessary burden. At CFC, we see it as a welcome barrier to entry.
A system that requires this level of accountability will naturally weed out lower-quality agencies that prioritize growth over compliance. Audit-proofing ourselves isn’t just about following the law. It is about ensuring that every family we serve is protected from future state clawbacks or loss of benefits due to improper documentation.
A Career Built on Truth
The family caregiver career is uniquely challenging. It requires advocacy, high-acuity skill, and emotional resilience. You deserve a partner who respects that career enough to be above board in every interaction.
As we move toward our launch in early 2026, we are building CFC to be the compliance leader in Colorado. We are not here to offer you pre-packaged answers. We are here to offer you a professional partnership that understands the full scope of your needs and the rigorous requirements of the law.
Monitoring the Landscape
It is important to remember that Rule 8.7420 is currently a proposal for stakeholder review. As a draft for stakeholder feedback, the specific language and implementation dates may shift as HCPF listens to the community.
At Caregivers First Choice, we will continue to monitor how these rules shake out. Our commitment is to remain at the forefront of these changes, ensuring that our marketing practices and our partnerships with families are not only ethical but also audit-proof from day one. We believe that true accountability isn’t just a rule to follow; it is the foundation of the care we provide.
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