Skip to Main Content
National Association for Home Care & Hospice
Twitter Facebook Pintrest


In the various roles he has undertaken through the years, Val J. Halamandaris has been a singular driving force behind the policy and program initiatives resulting in the recognition of home health care as a viable alternative to institutionalization. His dedication to consumer advocacy, which enhances the quality of life and dignity of those receiving home health care, merits VNA HealthCare Group’s highest recognition and deepest respect. 

VNA HealthCare Group

I have the highest respect for them, especially for the nurses, aides and therapists, who devote their lives to caring for people with disabilities, the infirm and dying Americans.  There are few more noble professions.

President Barack Obama

Home health care agencies do such a wonderful job in this country helping people to be able to remain at home and allowing them to receive services

U.S. Senator Debbie Stabenow (D-MI) Chair, Democratic Steering and Outreach Committee

Heath care at home…is something we need more of, not less of.  Let us make a commitment to preventive and long-term care.  Let us encourage home care as an alternative to nursing homes and give folks a little help to have their parents there.

Former President Bill Clinton

Home care is a combination of compassion and efficiency.  It is less expensive than institutional care...but at the same time it is a more caring, human, intimate experience, and therefore it has a greater human’s a big mistake not to try to maximize it and find ways to give people the home care option over either nursing homes, hospitals or other institutions

Former Speaker of the U.S. House of Representatives Newt Gingrich (R-GA)

Medicaid covers long-term care, but only for low-income families.  And Medicare only pays for care that is connected to a hospital discharge....our health care system must cover these vital services...[and] we should promote home-based care, which most people prefer, instead of the institutional care that we emphasize now.

Former U.S. Senator Majority Leader Tom Daschle (D-CD)

We need incentives to...keep people in home health care settings...It’s dramatically less expensive than long term care.

U.S. Senator John McCain (R-AZ)


Home care is clearly the wave of the future. It’s clearly where patients want to be cared for. I come from an ethnic family and when a member of our family is severely ill, we would never consider taking them to get institutional care. That’s true of many families for both cultural and financial reasons. If patients have a choice of where they want to be cared for, where it’s done the right way, they choose home.

Donna Shalala, former Secretary of Health and Human Services

A couple of years ago, I spent a little bit of time with the National Association for Home Care & Hospice and its president, Val J. Halamandaris, and I was just blown away. What impressed me so much was that they talked about what they do as opposed to just the strategies of how to deal with Washington or Sacramento or Albany or whatever the case may be. Val is a fanatic about care, and it comes through in every way known to mankind. It comes through in the speakers he invites to their events; it comes through in all the stuff he shares.

Tom Peters, author of In Search of Excellence

Val’s home care organization brings thousands of caregivers together into a dynamic organization that provides them with valuable resources and tools to be even better in their important work. He helps them build self-esteem, which leads to self-motivation.

Mike Vance, former Dean of Disney and author of Think Out of the Box

Val is one of the greatest advocates for seniors in America. He goes beyond the call of duty every time.

Arthur S. Flemming, former Secretary of Health, Education, and Welfare

Val has brought the problems, the challenges, and the opportunities out in the open for everyone to look at. He is a visionary pointing the direction for us. 

Margaret (Peg) Cushman, Professor of Nursing and former President of the Visiting Nurses Association

Although Val has chosen to stay in the background, he deserves much of the credit for what was accomplished both at the U.S. Senate Special Committee on Aging, where he was closely associated with me and at the House Select Committee on Aging, where he was Congressman Claude Pepper’s senior counsel and closest advisor. He put together more hearings on the subject of aging, wrote more reports, drafted more bills, and had more influence on the direction of events than anyone before him or since.

Frank E. Moss, former U.S. Senator

Val’s most important contribution is pulling together all elements of home health care and being able to organize and energize the people involved in the industry.

Frank E. Moss, former U.S. Senator

Anyone working on health care issues in Congress knows the name Val J. Halamandaris.

Kathleen Gardner Cravedi, former Staff Director of the House Select Committee on Aging

Without your untiring support and active participation, the voices of people advocating meaningful and compassionate health care reform may not have been heard by national leaders.

Michael Sullivan, Former Executive Director, Indiana Association for Home Care

All of us have been members of many organizations and NAHC is simply the best there is. NAHC aspires to excellence in every respect; its staff has been repeatedly honored as the best in Washington; the organization lives by the highest values and has demonstrated a passionate interest in the well-being of patients and providers.

Elaine Stephens, Director of Home Care of Steward Home Care/Steward Health Systems and former NAHC C

Home care increasingly is one of the basic building blocks in the developing system of long-term care.  On both economic and recuperative bases, home health care will continue to grow as an essential service for individuals, for families and for the community as a whole.

Former U.S. Senator Olympia Snowe (R-ME)

NCOA is excited to be part of this great event and honored to have such influential award winners in the field of aging.

National Council of Aging

California Supreme Court Finds That Caregiver Assumes Risks with Dementia Patients

August 12, 2014 04:20 PM

The Supreme Court of California issued a very detailed ruling on the rights of health care workers who are injured in caring for patients with Alzheimer’s disease and other dementias. In its ruling, the court held that health care workers employed to care for individuals with dementia assume the risk of injury caused by their clients who suffer from a disease that manifests itself in agitation and physical aggression. The case is the first known of its kind in the nation, and it extends a fairly well-settled principle “that those hired to a hazardous condition may not sue their clients for injuries caused by the very risks they were retained to confront.”

In Gregory v. Cott, the California Supreme Court addressed the claims brought by a personal care worker employed by a home care agency against one of her clients and the client’s spouse. The worker sought damages for injuries caused the client when the client bumped into the worker as she was engaged in housekeeping tasks. Specifically, the worker lost control of a knife when she was bumped, the knife injured her hand, and she ended up with a series of injuries from the knife wound. The worker received protections under the agency’s worker compensation coverage, but also sued the client for damages.

The court applied a principle of law known as primary assumption of risk to reject the worker’s claims. Under that principle, there is no duty breached by a party when an injury occurs in a hazardous situation where risks are inherent in the nature of the employment. The court reviewed earlier cases throughout the nation where the principle was applied to firefighters, veterinarians, and health care workers in an institutional setting.

The court, in a divided opinion, held that the principle can apply equally in the home care setting as well as in nursing homes and hospitals. Also, no exceptions apply because the worker is a nonprofessional or receiving limited wages.

The court found that the extension of the general rule from institutional care to a home care setting was reasonable in light of the nation’s overall policy of encouraging home care over institutional care, demonstrated by various legal reforms including the US Supreme Court decision in Olmstead v. L.C.  that  held that Medicaid beneficiaries are entitled to care in the least restrictive environment under the Americans with Disabilities Act.

In this case, the worker and her employer were aware of the nature of the client’s condition and her needs. The needs were triggered by her dementia. As such, the risks of caring for the client were known and expected while the worker was employed in the client’s household specifically to deal with needs stemming from a condition that created a hazardous environment.

The case offers a few lessons to home care agencies:

First, the agency-employer should make sure that the assigned workers are fully aware of the care setting and client’s condition on all assignments. This will help manage risks and put competent workers into the care of clients.

Second, home care agencies should provide adequate training and support for workers specific to the nature of the clients they serve. For example, serving clients with a form of dementia requires directed training and support that is different than providing services to individuals with physical disabilities.

Third, agencies should take all reasonable measures to reduce foreseeable risks in the home care environment that are due to any hazardous condition related to the nature of the client and her care needs. 

These steps help manage risks that a worker will be injured, clients needs will not be met , and agencies will fail to adhere to community standards of practice and/or licensing laws and accreditation standards. In addition, it will reduce the risks of litigation that involves any and all of the stakeholders involved.      

The decision in Gregory v. Cott was issued by the California Supreme Court on August 4, 2014. The decision can be found here.




©  National Association for Home Care & Hospice. All Rights Reserved.