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The Revenue Neutral Caregiver provides weekly analysis of policy, budget priorities, and legislative strategy through the lens of caregiver infrastructure. Each essay examines how Colorado can modernize workplace protections, address fiscal constraints, and strengthen governance capacity.
Policy Analysis Has Moved
The Revenue Neutral Caregiver publishes exclusively on Substack for better email delivery, reader engagement, and streamlined publishing.
All weekly policy analysis, legislative updates, and caregiver infrastructure essays are now available on our Substack newsletter.
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March 7, 2026
Part of the Weekly Pulse analysis series on Substack, this essay argues that because federal courts have retreated from their role as constitutional ballasts, states must pass the Colorado CARE Act to provide durable, state-level legal architecture that protects caregivers from the economic and institutional shocks of executive overreach.
March 1, 2026
Part of the Weekly Pulse analysis series on Substack, this essay continues the exploration of institutional capacity and caregiver infrastructure reform. It argues that a "legislative vacuum" left by Congress has forced caregivers into a precarious system governed by unstable executive memos rather than durable laws.
Policy Analysis Has Moved
The Revenue Neutral Caregiver publishes exclusively on Substack for better email delivery, reader engagement, and streamlined publishing.
All weekly policy analysis, legislative updates, and caregiver infrastructure essays are now available on our Substack newsletter.
See Recent Weekly Pulse Posts
March 7, 2026
Part of the Weekly Pulse analysis series on Substack, this essay argues that because federal courts have retreated from their role as constitutional ballasts, states must pass the Colorado CARE Act to provide durable, state-level legal architecture that protects caregivers from the economic and institutional shocks of executive overreach.
March 1, 2026
Part of the Weekly Pulse analysis series on Substack, this essay continues the exploration of institutional capacity and caregiver infrastructure reform. It argues that a "legislative vacuum" left by Congress has forced caregivers into a precarious system governed by unstable executive memos rather than durable laws.
April 11, 2026
The expertise outside the room. This week's analysis connects a Saturday morning parking lot in Denver — where Rose waits in the car with a magazine that has her name on it — to the New York Times reconstruction of how Operation Epic Fury began, to the 661-page Long Bill being read aloud to an empty Colorado chamber, and to the meeting where Mark Fukae was told his caregiving situation wasn't different and left promising to change the law. Same structural failure at every scale: the people absorbing the consequences were outside the room where decisions were made. The Colorado CARE Act puts them in the statute. 2027 session. Zero general fund cost.
Policy Analysis Has Moved
The Revenue Neutral Caregiver publishes exclusively on Substack for better email delivery, reader engagement, and streamlined publishing.
All weekly policy analysis, legislative updates, and caregiver infrastructure essays are now available on our Substack newsletter.
See Recent Weekly Pulse Posts
April 4, 2026
A microscope can find a cell, but our systems can’t find a caregiver. This week's analysis examines what the mounting $1.2B state deficit, the ripple effects of the DHS "Black Hole," and the shifting landscape of the 2026 midterms look like when they collide with a single caregiving household - and why the Colorado CARE Act for 2027 is designed to pull caregivers like Rose out of the legislative shadows. We aren’t just looking for a solution; we’re building an enforceable process that recognizes the person behind the patient.
March 21, 2026
When the executive claims everything and the legislature records nothing, someone still has to hold the line. Part VI of 21st Century Guardrails examines what broad authority without guardrails actually costs — and why Colorado's CARE Act does what a functional legislature should: writes the law, defines the protection, holds the record.
March 14, 2026
21st Century Guardrails - A Caregiver Lens - Part V - Repair the Legislature
This Weekly Pulse analysis examines legislative abandonment through a caregiver lens—why broad authority without guardrails creates constitutional crisis, and why Colorado's CARE Act does what a functional legislature should: writes the law, defines the protection, holds the record.
Policy Analysis Has Moved
The Revenue Neutral Caregiver publishes exclusively on Substack for better email delivery, reader engagement, and streamlined publishing.
All weekly policy analysis, legislative updates, and caregiver infrastructure essays are now available on our Substack newsletter.
See Recent Weekly Pulse Posts
Part of the Weekly Pulse analysis series on Substack, this essay argues that because federal courts have retreated from their role as constitutional ballasts, states must pass the Colorado CARE Act to provide durable, state-level legal architecture that protects caregivers from the economic and institutional shocks of executive overreach.
March 1, 2026
Part of the Weekly Pulse analysis series on Substack, this essay continues the exploration of institutional capacity and caregiver infrastructure reform. It argues that a "legislative vacuum" left by Congress has forced caregivers into a precarious system governed by unstable executive memos rather than durable laws.
Policy Analysis Has Moved
The Revenue Neutral Caregiver publishes exclusively on Substack for better email delivery, reader engagement, and streamlined publishing.
All weekly policy analysis, legislative updates, and caregiver infrastructure essays are now available on our Substack newsletter.
See Recent Weekly Pulse Posts
March 7, 2026
Part of the Weekly Pulse analysis series on Substack, this essay argues that because federal courts have retreated from their role as constitutional ballasts, states must pass the Colorado CARE Act to provide durable, state-level legal architecture that protects caregivers from the economic and institutional shocks of executive overreach.
March 1, 2026
Part of the Weekly Pulse analysis series on Substack, this essay continues the exploration of institutional capacity and caregiver infrastructure reform. It argues that a "legislative vacuum" left by Congress has forced caregivers into a precarious system governed by unstable executive memos rather than durable laws.
Policy Analysis Has Moved
The Revenue Neutral Caregiver publishes exclusively on Substack for better email delivery, reader engagement, and streamlined publishing.
All weekly policy analysis, legislative updates, and caregiver infrastructure essays are now available on our Substack newsletter.
See Recent Weekly Pulse Posts
March 21, 2026
When the executive claims everything and the legislature records nothing, someone still has to hold the line. Part VI of 21st Century Guardrails examines what broad authority without guardrails actually costs — and why Colorado's CARE Act does what a functional legislature should: writes the law, defines the protection, holds the record.
The Revenue Neutral Caregiver publishes exclusively on Substack for better email delivery, reader engagement, and streamlined publishing.
All weekly policy analysis, legislative updates, and caregiver infrastructure essays are now available on our Substack newsletter.
See Recent Weekly Pulse Posts
August 1, 2026
The Infrastructure We Build - Dispatch One
The Colorado Commission on Medicaid met for five hours on July 28. The testimony was substantive. The commissioners were engaged. Not once did anyone surface the family caregiver-to-institutionalization cost curve.
That is CASI's opening.
On July 28, CASI completed both the Commission's long-form stakeholder survey and its anonymous short form - delivering the N_crit argument, the preemption gap analysis, and a formal request for a presentation opportunity. On the same day, CASI received a direct, named invitation to attend office hours with Summer Gathercole, the Commission's facilitating organization - virtual session, August 4, 9am.
The target: a presentation slot at the August 20 or September 2 Commission meeting. The argument is built. The Caring Costs Survey is in active revision between v5.3 and v5.4. The CARE Act has a fiscal note, a revised Section 1, and a Senate sponsor deadline of September 30.
The gap wasn't in the room. CASI is putting it there.
August 1, 2026
The Infrastructure We Build - Dispatch One
The Colorado Commission on Medicaid met for five hours on July 28. The testimony was substantive. The commissioners were engaged. Not once did anyone surface the family caregiver-to-institutionalization cost curve.
That is CASI's opening.
On July 28, CASI completed both the Commission's long-form stakeholder survey and its anonymous short form - delivering the N_crit argument, the preemption gap analysis, and a formal request for a presentation opportunity. On the same day, CASI received a direct, named invitation to attend office hours with Summer Gathercole, the Commission's facilitating organization - virtual session, August 4, 9am.
The target: a presentation slot at the August 20 or September 2 Commission meeting. The argument is built. The Caring Costs Survey is in active revision between v5.3 and v5.4. The CARE Act has a fiscal note, a revised Section 1, and a Senate sponsor deadline of September 30.
The gap wasn't in the room. CASI is putting it there.
July 25, 2026
The Long Game - Dispatch 4
The second dispatch of The Infrastructure We Build documents two significant developments from the week of August 4–8, 2026.
Legislative track: CARE Act v5.4 responded to DORA's formal written objection by restructuring the interactive process accommodation framework into a standalone statutory section, C.R.S. § 24-34-402.5, with a firewall clause modeled on SB23-172. Disability Justice confirmed no technical conflicts. The Lockwood meeting with the CCRD sunset review analyst is confirmed for August 21. September 30 remains the Senate sponsor deadline.
Petition track: Change.org data reveals that 10 promoters contributing $453 have generated 17,669 petition views and 580 of the petition's 722 total confirmed signatures — 80% of all signatures received. At current rates, $1 of petition promotion generates approximately 39 views and 1.3 signatures. The petition goal is 1,000. The gap is 278.
July 25, 2026
The Long Game - Dispatch 4
Dispatch Four of The Long Game is live.
The Colorado CARE Act is at v5.4. This week: a technical review with DORA's civil rights leadership. Two problems surfaced. Both answered - with a full legal research memo and a seven-section fiscal note built from CCRD's own historical data.
The number that matters: the bill's $237,229 ongoing annual cost is fully offset if it prevents 12 individuals from entering institutional nursing facilities. Twelve people. Out of 910,000 Colorado family caregivers. The bill pays for itself at 0.0013% of the at-risk population.
Also this week: the Caring Costs Survey framework is in the Medicaid Commission record. Confirmation pending with Commission facilitators.
Senate sponsor deadline: September 30.
July 18, 2026
Our Lives On Hold "Before She Comes Home"
This week's dispatch from The Revenue Neutral Caregiver documents what discharge preparation actually looks like - and what it costs when a family has the resources to do it, and what happens when they don't.
CASI Founder Mark Fukae's mother Rose, 94, is being discharged from Julia Temple skilled nursing facility in Englewood on July 23. Kaiser's home care team will conduct a Tuck In safety assessment on July 24. The family has spent this week acquiring a commode, bathing bench, entry ramp, and gait belt for two-person transfers while Rose remains zero weight bearing. An orthopedic appointment is scheduled July 29 in Lone Tree - over an hour from the family's home in Brighton.
Kaiser's team noted the family is unusually prepared.
The dispatch uses that observation as a diagnostic lens: the system discharges patients into prepared and unprepared households with the same paperwork and sees neither. Families who cannot absorb discharge preparation - financially, spatially, or logistically - reach Medicaid faster, at greater cost to the state.
The verified 2026 Colorado Medicaid long-term care figures are named plainly: $2,000 asset limit, $2,982 income ceiling, $10,200 average monthly nursing home cost without Medicaid, and a 60-month look-back on all asset transfers. The community spouse resource allowance of approximately $154,140 is named alongside what it actually means in practice.
The dispatch also notes that CASI's July 7 stakeholder submission to the Colorado Commission on Medicaid - followed up July 9 - remains unconfirmed as of publication. The Caring Costs Survey v5.3, in active audit for v5.4, is the instrument designed to produce the arrangement-failure rate data the Commission's fiscal model is currently missing.
October 24, 2026
The Research Desk #5 - Colorado Is About to Count Caregivers
HCPF's draft Family Caregiver Verification Form will determine who qualifies for the family caregiver exemption from the federal Medicaid work requirement (beginning Jan. 1, 2027; 80 hours a month). It covers caregivers of a child 13 or younger or of a person with "a disability or serious complex medical condition that is life threatening, or makes performing daily activities difficult," with examples including shopping, housework, cooking and transportation. Caregivers who live with the person report no hours; relatives elsewhere check the months they gave care; unrelated non-residents answer an 80-hour question.
The federal rule (91 FR 33348, June 3, 2026).
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Through 2027, states "may require documentation or accept other information."
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From Jan. 1, 2028, states "must require documentation if documentation is reasonably available," and must accept other information when none is.
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Caregiver criteria apply to paid and unpaid caregivers alike.
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States "may not require the name of the individual receiving care."
CASI's comments to HCPF. Count paid caregiving; allow more than one care recipient; state plainly that names and medical records aren't required; list 2028 documents and the alternative now; at least 30 days to respond, with coverage continuing; quarterly public counts of caregiver exemptions; Spanish with English.
Deadline: feedback through Saturday, October 31. 📄 Form: https://hcpf.colorado.gov/sites/hcpf/files/HFC%20FINAL%20MVP%20Family%20Caregiver%20Verification%20Form%20New%20vs%20Renewal_A.pdf✍️
Next. HCPF says it will report back on its five LTSS proposals the week of Oct. 26. HCPF's H.R. 1 webinar: Monday, Oct. 26, 10 a.m.
Policy Analysis Has Moved
The Revenue Neutral Caregiver publishes exclusively on Substack for better email delivery, reader engagement, and streamlined publishing.
All weekly policy analysis, legislative updates, and caregiver infrastructure essays are now available on our Substack newsletter.
See Recent Weekly Pulse Posts
October 17, 2026
The Research Desk #4 - What would it cost to let caregivers ask?
This week's Research Desk delivers the plan promised on October 10: how the FLEX Act and the CARE Act work as two phases, and what phase one would cost.
The gap. The Center for WorkLife Law counted more than 250 state and local governments with caregiver protections as of April 2023. Colorado's entry reads "No state law."
The plan.
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FLEX Act (2027 session): a right to request a flexible arrangement; written acknowledgment and a written decision on set timelines; denial allowed for enumerated business reasons; no retaliation; no new leave.
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CARE Act (2029 to 2030): caregiver status added to the Colorado Anti-Discrimination Act.
Cost precedents (documents opened and logged).
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SB20-205, paid sick leave (LCS Final Fiscal Note, Sept. 8, 2020): 480 complaints a year assumed, 25% needing full investigation at about 40 hours each; $298,196 and 3.5 FTE a year from FY 2021-22; General Fund appropriation in year one.
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Vermont, 21 V.S.A. § 309 (effective Jan. 1, 2014): the enacting act (Act 31 of 2013) contains no appropriation and no new positions; enforcement through existing offices.
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UK impact assessment (Oct. 21, 2024): costs of accommodating requests "are considered discretionary" and not included.
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FLEX asks more than Vermont's law: deadlines, written notice before revocation, a division report to the legislature, and a private right of action after the administrative process. CASI does not claim it would be free.
Records. FLEX v1.6 would require employers to keep acknowledgments, decisions and notices for three years, available to the Division of Labor Standards and Statistics. By Nov. 1, 2030, the division would report to the legislature on complaints and civil actions, the most frequent grounds for denial, and, with HCPF where data allow, flexibility and caregiver retention, with a recommendation on phase two.
Next.
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HCPF says it will report back on its five LTSS proposals the week of October 26, with a formal comment period to follow.
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HCPF's webinar on H.R. 1 (federal Medicaid changes, including work requirements and the caregiver exemption): Monday, October 26, 10 a.m.
October 10, 2026
The Research Desk #3 - Who Absorbs the Cost?
This week's Research Desk, Who Absorbs the Hours?, looks at the five proposals HCPF presented at its October 6 and 7 roundtables.
What HCPF is considering (preliminary General Fund savings estimates, per HCPF's Policy Impact Summaries; some are alternatives, so they should not be added together):
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Lower the Homemaker limit to about 7 hours a week for all members. About 34,000 members are authorized above that. Narrow exceptions and appeal rights. About $12 million.
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Limit paid Homemaker hours from family caregivers to about 7 a week per member. No exceptions. About $29 million.
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Move children's Personal Care out of Community First Choice. About 5,500 children. About $17 million.
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Lower the Personal Care limit from about 48 to about 40 hours a week. About 3,800 people. Appealable. About $9 million.
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Limit parents and legal guardians of minors to 7 paid hours of Personal Care a week. A hard cap. About $11 million.
What HCPF says it doesn't know. For concepts 2 and 5: "HCPF does not have paid family caregiver data." For concept 5, HCPF "does not currently know the number" of families affected.
What HCPF names as risks. For concept 3: "families may provide some care without payment or members could experience gaps in care." For concepts 3 and 4, some members "may seek Long-Term Home Health or other services… Because some of these services cost more, this could reduce the savings." At the roundtable, HCPF said concept 3 "could create a bigger reliance on uncompensated care, unpaid care."
What CASI asked for. Track nursing facility admissions, hospitalizations and emergency visits among members whose hours or caregivers change, starting as the weekly caregiver cap steps down from 84 to 70 hours in January; publish savings and a break-even estimate for every concept; and keep an exception when no appropriate alternative caregiver exists.
Next.
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HCPF feedback survey closes Sunday, October 11.
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HCPF says it will report back the week of October 26, with a formal comment period before anything goes to federal regulators.
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Next week on The Research Desk (October 17): how the FLEX Act (2027) and the CARE Act (2029–2030) work as two phases of one plan.
October 3, 2026
The Research Desk #2 - 8 Percent
8 percent of Colorado's Medicaid members use long-term services and supports. They account for about 48 percent of Medicaid's General Fund spending.
In today's Research Desk, CASI founder Mark Fukae looks at what that number shows and what it leaves out:
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The state budget office projects a $443 million Medicaid overspend this year, driven by how much care people use, not by enrollment.
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The weekly caregiver cap (84 hours now, 70 in January, 56 in July 2027) is projected to save about $1.1 million in General Fund money in year one: about a quarter of one percent of that overspend.
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By CASI's calculation from the state's own figures, those savings would be offset if about 54 families moved someone into a nursing facility. That is a threshold, not a prediction. No one is measuring it.
CASI has asked the Medicaid Commission to recommend that HCPF track nursing facility admissions among members affected by the cap.
The piece also corrects an error in last week's correction ledger: the cap is phased, not immediate.
Have your say: HCPF roundtables are October 6 (1:00–2:30 p.m.) and October 7 (9:00–10:30 a.m.), with a written survey open through October 11.
September 26, 2026
The Research Desk #1 - Back to Baseline
This week CASI's founder, Mark Fukae, published Back to Baseline, the first piece in a new series, The Research Desk.
The correction. Figures CASI previously cited for the cost difference between nursing facility and home-based care ($33,614) and for the threshold called Ncrit (33) are retired. The state's own 2023 transition report shows about $40,712 per person per year for the population it studied; the corrected Ncrit is about 54 families in year one and 76 ongoing. Savings projections built on the earlier figures are withdrawn. The full correction ledger is published with the essay and governs anything CASI has published before.
What the evidence shows. Paid family leave has been shown to reduce nursing home use (Arora & Wolf, 2018). Hybrid work has been shown to reduce quitting (Bloom, Han & Liang, Nature, 2024). Heavy caregiving, more than about ten hours a week, pulls people out of work (Lilly, Laporte & Coyte, 2007).
What it doesn't. We found no study that follows an employed caregiver from a flexible arrangement at work to whether their care arrangement at home holds, and no Colorado data source we've found asks. That is CASI's research focus.
What's happening now.
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The Caring Costs Survey is live in English and Spanish, with six- and twelve-month follow-up being added. It is not a random sample; it documents how working caregivers lose their footing.
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The proposed FLEX Act would give employed caregivers a way to request flexibility, require a written answer, and begin measuring whether it works.
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CASI is seeking a research partner able to link employment and care outcomes.
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Coming up: HCPF personal care and homemaker roundtables, Oct. 6 (1:00–2:30 p.m.) and Oct. 7 (9:00–10:30 a.m.). Final Medicaid Commission meeting before its report, Oct. 7.
September 19, 2026
Infrastructure We Build - Dispatch 6 - The $768 Million Question
Thursday's Colorado Commission on Medicaid meeting confirmed $1.3–$1.5 billion in combined Medicaid budget impact - in one fiscal cycle.
CASI's analysis translates that number into a mechanism:
Nmacro=13,179 - forced institutional conversions generating the $443M overspend. 1.4% of Colorado's caregivers.Ncrit=33 - the threshold below which any service cut erases its own savings. N=268 (0.06%) - the FLEX Act's annual break-even. Less than a rounding error on HCPF's forecasting miss.
The two-phase Colorado Care Firewall - FLEX Act (Title 8, 2027) and CARE Act (Title 24, 2029-2030) - projects $768.92 million in cumulative Medicaid cost avoidance over ten years. Zero appropriation.
The Caring Costs Survey is the measurement instrument that turns this directional model into primary Commission evidence.
Current response count: 2 total. Zero on Modules 2-4. Zero in Spanish.
This is the moment where the data either exists or it doesn't. Take the survey today: casiadvocacy.org/research
Módulos 1 y 3 disponibles en español. Tu experiencia es la evidencia.
September 13, 2026
Our Lives On Hold - What the Pipes Sounded Like
Yesterday I stood in a field in Estes Park and listened to bagpipes while the week kept running in my pocket.
The Caring Costs Survey is live at casiadvocacy.org/research. Module 1 takes 90 seconds. If you are a caregiver, a policy advocate, or an employer - there is a door for you. Anonymous. No account required. Now available in English and Spanish.
736 people have signed the petition to pass the Colorado CARE Act. The Commission meets December 11. Your response is the data.
September 5, 2026
The Infrastructure We Build - Dispatch 5
The Caring Costs Survey is live at casiadvocacy.org/research.
It was built to give a name to the invisible labor that has kept the economy moving for generations — the pivot, the swap, the simultaneous management of two people's needs at ten o'clock at night that no employer knows about and no legal framework currently recognizes.
Four modules. Academically reviewed by Dr. Chloe East at CU Boulder. Designed to inform the Colorado Commission on Medicaid's December 11 report and the 2027 CARE Act legislative session.
Caregivers, policy advocates, and employers each have a door. Anonymous. No account required.
Read the full dispatch on Substack and take the survey today.
August 29, 2026
The Infrastructure We Build - Dispatch 4
Two independent Colorado attorneys have now reviewed the Colorado CARE Act's independence provision — the clause that decouples accommodation rights from leave eligibility — and reached the same conclusion: no preemption problem. The provision holds.
The same week, Senator Mike Weissman, who chairs the Judiciary Committee in the Colorado Senate, confirmed that the lack of immutability is not a legal barrier to protected class status for family caregivers.
The legal argument is won. The political argument — enforcement mechanism, coalition, sponsor — is next.
IWB Dispatch 4 documents the week from the inside: the legal clearance, the CCRD sunset criteria mapped to the CARE Act by Friday afternoon, the Commission on Medicaid recorded on August 27 — review pending, and the Caring Costs Survey now live at casiadvocacy.org/research.
Read the full dispatch on Substack.