Professional Documents
Culture Documents
DEPARTMENT OF HEALTH
Olympia, Washington 98504
Enclosed is a copy of all rebuttal comments received regarding the CHI Franciscan
Health application proposing to relocate 242 of the 253 acute care beds from the
Bremerton campus to the Silverdale campus.
These rebuttal comments are provided for your information only; responses to rebuttal
comments will not be accepted.
If you have any questions regarding the rebuttal process, you can call me directly at
(360) 236-2957 or e-mail me at karen.nidermayer@doh.wa.gov.
Sincerely,
The Bremerton campus opened in 1965. The West wing was added in 1970 and various other
additions occurred over the period of 1978-2002. Today, the newest inpatient rooms at
Bremerton are 32 years old, and 60% of the inpatient beds are in semi-private rooms. An
analysis commissioned by CHI Franciscan concluded that an investment of about $212 million
was needed at Bremerton to simply maintain current operations at that campus. However, even
with that investment, two campuses are not efficient and investment well beyond the $212
million would be needed to keep pace with demand, technology and service development. Once
consolidated in 2023, operating cost reductions associated with improved efficiencies and
operating a single campus are currently estimated at more than $9 million annually.
Importantly and per CHARS, more than three-quarters of the patients admitted to a Harrison
location (Bremerton or Silverdale) reside equidistant or closer to the Silverdale Campus. As
such, Silverdale is not only newer, and not only has the space for growth; it is also either as
accessible or more accessible to the majority of our patients.
This project, in Phase 1, proposes to construct a nine (9) story tower that will house acute care
beds, an emergency department, a cancer center, diagnostic imaging, and ancillary and support
services (pharmacy, laboratory, central supply, etc.). Phase 1 will relocate 168 acute care beds to
Silverdale by January 1, 2020 (144 beds in a new tower and 24 beds in the existing hospital).
Phase 2, which will relocate the remaining 74 beds, includes the construction of a second new
tower and will open by 2023.
At the completion of Phase 1, Silverdale will operate with 238 acute care beds and 24 neonatal
beds (for a total of 262 beds). Phase 2 will include a total of 312 acute care beds and 24 neonatal
beds, for a total of 336 beds. As part of this project, upon CN approval, Harrison will relinquish
the 11 bed license it retains related to inpatient psychiatric beds. As such, Harrisons licensed
beds will decrease from 347 to 336 beds.
1
As the planning for this project progressed, Harrison engaged the public at numerous times. The
project enjoys widespread support as evidenced by the following excerpts from the public
record:
We have a wonderful birthing center in Silverdale. The ICU is in Bremerton. On the rare
occasion that we have an OB patient that requires an ICU, we wind up having to transport a
very ill patient to Bremerton for care. Once out of ICU they then have to be transported back to
Silverdale because there is no post-partum service in Bremerton. The same is true for any
Gynecologic post-operative surgery patients that wind up with complications. This is not an
ideal situation, as it causes delay in treatment and adds costs.
Anita Alvestad-McIntyre, MD, February 2, 2017
The KPHD participated in HMCs six month Bremerton Community Health Care Advisory
Group process, which engaged community and agency leadership in data driven discussion
about the benefits and consequences of the Hospitals move to Silverdale. Harrison Medical
Center also surveyed 500 Kitsap County Residents to learn their perspectives on the same topics.
Themes that emerged from both processes include:
Appreciation for the development of a state of the art Facility providing similar or better
access to hospital facilities by most Kitsap residents;
Understanding that the cost of preserving and extensively renovating the Bremerton
facility would be prohibitive;
Converses regarding potential longer drive times and EMS transit time to the Silverdale
emergency department and hospital from downtown Bremerton and East Bremerton;
Request that Harrison retain or return important outpatient services in Bremerton,
including urgent care services, medical oncology and obstetrical medical care,
radiologic imaging services, primary care services, lab services, outpatient behavioral
health services, oral health care, substance abuse treatment services with a 24hr
pharmacy.
Susan Turner MD, MPH, MS, Health Officer, Kitsap Public Health District, February 14, 2017
There are many priorities of a health care organization and I dont have the time to touch upon
them all. As a board; however, we recognize that those who are sick, vulnerable, scared and in
need deserve access to the best quality health care. We are at a point in time where the
affiliation with CHI-Franciscan has made it possible to build a state-of-the art facility for the
residents of Kitsap County and the Greater Olympic Peninsula.
Raquel (Kelly) R Nelson, Board Chair, Harrison Medical Center, February 11, 2017
By relocating this facility, there is opportunity to build the hospital up to current fire
and life-safety codes, including advanced built-in fire and smoke protection systems
that are not currently available at the Bremerton facility. The compartmentation and
built-in systems will provide enhanced safety for occupants, visitors, employees, and
firefighters responding to emergencies.
Scott Weninger, Fire Chief, Central Kitsap Fire & Rescue, February 21, 2017
2
Moving the existing hospital licensed beds to Silverdale will not only provide faster access
to care for the majority of our county but also will bring those services up to todays
standards for infection control and privacy. It is very difficult to have double rooms for
patients in todays healthcare environment.
Patricia Cochrell, Poulsbo resident, former nurse, Harrison Medical Center, February 21, 2017
The new Silverdale facility will provide the space, privacy, and comforting milieu to further
enhance the care we provide our patients and their families under these difficult
circumstances. With now more than 3 years of experience following the affiliation of Harrison
with CHI Franciscan Health I can unequivocally assure you that there has been no reductions
or limitations imposed upon the delivery of end-of-life care in the hospital. In fact, we have
enjoyed the further development of, and increased access to palliative care expertise and
services.
Griffith M. Blackmon, MD, MPH Medical Director Critical Care Services. February 21, 2017
As Kitsap County grows in population over the next 20 years, adding 80-100,000 residents, the
need for hospital care will increase proportionally. Harrison's location in Silverdale is much
better suited to handle patients, due to its close proximity to the freeway. It is also much
more centrally located to provide more convenience for more residents of Kitsap County,
especially those who live and work in the north end of the countyKitsap Countys
Comprehensive Plan, adopted in 2016, call s for increased density of housing units and jobs in
Silverdale. Harrison's Hospital expansion is an important part of the expected growth. CHI
Franciscan is the county's largest private employer, with thousands of jobs reliant on its
successFurthermore, the County is making long-term investments into Silverdale's
transportation infrastructure, including road capacity upgrades as well as pedestrian and
bicycle facilities. Kitsap County transportation investments in the next six years total $43
million.
Edward E. Wolfe, Kitsap County Commissioner, February 14, 2017
3
Harrison recognizes that a small cohort raised concerns about the project and we have
summarized their comments below:
1) Several raised conjectural access concerns related to the fact that Harrison, which is
secular, is owned by CHI Franciscan which operates under the Catholic Health
Initiatives Ethical and Religious Directives (ERDs). These individuals requested that the
CN Program not allow the expansion of Harrison until certain guarantees are imposed.
We note that not one of the persons expressing concern provided any evidence of any
patient being denied access to any service. Further, we note that this application is
neither about an expansion, nor about a new service or any service being eliminated.
This CN application simply seeks to consolidate Harrisons existing licensed bed
capacity onto a single campus in order to provide better, more accessible, and more
efficient quality patient care.
2) Several physicians, each of which is affiliated with one or more local health care facilities
expressed concern about the utilization of their respective facilities. In addition, they
made unsubstantiated comments that in most cases are factually inaccurate about costs of
care.
3) The City of Bremerton requested that the Program require about 100 beds to be
maintained in Bremerton. This would be costly both from a capital and operating
perspective, and would place the entire project in jeopardy. Harrison has assured, and will
continue to assure the City that its residentswhich are also our patientswill benefit
greatly by the project. In fact, while not part of this CN application, Harrison will be
constructing a large Ambulatory Care Center in Bremerton that will include primary care,
urgent care, and ancillary services and will also house our new Family Practice
Residency Program.
This rebuttal responds to each of these three concerns. The record should reflect that Harrison
will continue to engage each of these groups in an effort to better understand their concerns and
to provide data to inform the dialogue. Each of the groups, along with CHI Franciscan and
Harrison, share the same vision: providing accessible, quality care to residents of the Kitsap
Peninsula.
4
Concern #1: Harrison is secular; it does not operate under Catholic Health
Initiatives Ethical and Religious Directives (ERDs). The comments
from those that expressed concern, were conjectural in nature: not
one of the letters provided any evidence of any patient being denied
access to any service.
By Harrisons account, there were approximately 10 emails, letters or public comment statements
expressing concern about Harrisons secular status. We believe that 100% of these letters were
from Bainbridge Island residents. The comments largely verbatim restate or summarize the
public comments made by Mr. Barry Peters at the public hearing. After close review, Harrison
summarized the comments into two concerns: 1) concern over Harrison remaining secular in the
future, and 2) concern over the physician acquisitions that have occurred.
There is absolutely no interest or intent to revisit the secular nature of the Hospital which was the
subject of much negotiation prior to the affiliation. The record contains several letters of support
from individuals that were on the Board at the time of the negotiation. These letters reflect the
rigorous nature of the negotiations to ensure that Harrison remain secular. For example, and
according to a letter submitted by a Board member that participated in the negotiations Two very
important matters were negotiated-- abortions and end of life matters. Because Harrison had
never performed abortions, had no plans to begin to do so, and because alternative resources
were available and accessible in the community, we were able to agree to CHIs Ethical and
Religious Directives. In addition, it must be noted for the record that as part of our affiliation, a
Community Board was established to oversee womens reproductive services at Harrison. The
intent was to assure the Board and community that the services that had previously been in place
remained in place. Post affiliation, this Community Board and our various OB/GYN providers
have indicated that there is absolutely no change in the way womens services operate at
Harrison. (Letter of support, James T. Civilla, January 30, 2017)
5
Mr. Peters suggests that Harrison is monopolizing health care or somehow limiting choice
because of the acquisition of existing physician practices. Mr. Peters appears to not understand
the real reasons underlying the rate of physician acquisition increases in Kitsap County,
Washington State and the nation over the past 5+ or so years. Very few hospitals or systems
actively seek to employ physicians; as the practice itself typically requires ongoing subsidy.
The reality is that increasingly providers are approaching hospital systems requesting
employment. This includes new, younger physicians that have little or no interest in establishing
a private practice or even joining an independent group. It also includes long-standing private or
group practice providers that have determined they can no longer generate the revenues nor make
the investments needed to stay current with CMS. These providers are also concerned with
factors such as declining payments and decreased bargaining power with commercial payers and
uncertainty about future reimbursement and delivery models enacted by the Affordable Care Act
such as MACRA and MIPS. An August 3, 2015 article published in Medical Practice Insider
entitled Why doctors are leaving private practice noted (a copy is included in Appendix 1):
Doctors are leaving private practice in increasing numbers, with just one third expected to
continue working as independent practitioners by the end of 2016, a new study from
Accenture found.
The report, "Clinical care: The independent doctor will NOT see you now," found that the
number of independent physicians dropped from 57 percent in 2000 to 49 percent in 2015.
Accenture predicts that next year this number will drop further, to 33 percent, and
represents a 10 percent decline from Accentures 2012 report.
Two factors that physicians cited most often as their biggest concern with remaining
independent were reimbursement pressures and overhead cost, cited by 36 percent and 23
percent of respondents, respectively. With that, some independent doctors are choosing to
opt-out of public programs, such as Medicaid (cited by 26 percent of respondents), health
exchange plans (15 percent) and Medicare (3 percent).
"How the physician employment trend and its implications will unfold remains to be seen,"
the study said. "Other clinical care providers local hospitals, integrated health systems
and even retail clinics are likely to experience a shift in patient populations, a new payer
mix and healthcare delivery challenges as it evolves."
Acquisitions are necessary to ensure access. Had Harrison or CHI not acquired the practices a
significant number would have restricted patients by payer (Medicare and Medicaid) or would
have relocated from the County in order to align with a system that was willing to acquire them.
The reality is that Harrison preserved and enhanced access, not restricted it.
6
Mr. Peters repeatedly asks the CN Program to declare a pivotal unresolved issue in order to
assess the extent of Harrisons monopolization of the market (page 5), market changes that
might impact the need for the beds that Harrison currently has licensed and the extent to which
CHI Franciscan is imposing directives on independent doctors and providers (page 5). Mr.
Peters goes on to suggest that Harrisons WAC 246-320-141 policies are somehow not compliant
(page 6). Finally, Mr. Peters requests a litany of conditions that are unrelated to the project
(pages 7 and 8).
Again, Mr. Peters appears uninformed. Harrison does not monopolize the market. According to
CHARS data, Harrisons 2016 market share (Q1-Q3) of Kitsap County is 56.9%. Our market
share of Bainbridge Island is 27.8%. 1
Because Mr. Peters provided no evidence (or even anecdotes) as to how CHI Franciscan is
imposing directives on independent doctors and providers, it is nearly impossible for us to
respond to his comment. We can state however, other than standard credentialing and medical
staff bylawswhich every hospital in the State haswe have no authority over providers in
independent practices. Finally, Mr. Peters requests conditions be imposed that are unrelated to
the CN application seeking to consolidate our currently licensed beds. We are aware of no CN
decision ever, that eliminated licensed beds from an existing hospital. We further remind the CN
Program that WAC 246-310-490(3), entitled Conditional certificate of need allows the CN
Program to issue a conditional CN as long as the condition relates directly to the project being
reviewed.
(a) The secretary's designee in making his or her decision on a certificate of need
application may decide to issue a conditional certificate of need if the department finds
the project is justified only under specific circumstances: provided however, that
conditions shall relate directly to the project being reviewed and to review criteria.
This CN simply seeks to consolidate Harrisons existing beds on a single campus. We are not
adding beds or services, nor are we eliminating services. It must also be noted that not one
individual provided any example of any service being restricted, nor any patient not receiving
services that they requested or medically needed. More importantly, many of the letters,
including that of Mr. Peters stated explicitly that that they have been satisfied patients of
Harrison over the years.
The Peters public comment included two attachments. The first was an analysis conducted by
Ms. Nancy Field. The second was a report of the ACLU.
1
WA State CHARS. Inpatient only. Excludes normal newborns, psych and rehab.
7
Field Report
In terms of the Field report, there are several critical fallacies that should be corrected.
First, in terms of need and access (page 1), Field states that Harrison must provide a rationale
for retaining its current licensed bed capacity. Field also argues that the beds will be located at
substantially reduced travel times to Bainbridge and to rural communities on the Olympic
Peninsula. Harrison is already CN approved and licensed for 347 acute care beds. This project
does not seek to add beds. In screening, the CN Program never requested any analysis of the
continued need for the beds, and to our knowledge, the Program has never eliminated licensed
beds during the course of a CN review. The Field report is not correct related to the beds.
In terms of the distance from Bainbridge to the Bremerton and Silverdale campuses, the Field
report is correct and residents of Bainbridge Island will experience reduced travel times to
Silverdale. Field alludes that residents fear being referred or transported to an emergency room
and hospital that refuses to offer select services. Harrison is secular and there is no evidence in
the record or in the Field report to suggest that any resident will be refused any services.
Field suggests that Harrison did not appropriately respond to questions about access to care and
admission policies, and goes as far as stating that A review of the policies CHI/Harrison makes
available does not satisfy the requirements of the licensing law, but no specific deficiencies
were identified or noted. The fact is that Harrison fully addressed the questions related to access
and admission in our CN submittal. Further, we operate in full compliance with Department of
Health requirements. Specifically, in accordance with WAC 246-320-141(6), Harrisons policies
related to access to care (admission, nondiscrimination, end-of-life care and reproductive health)
have been provided to the Department of Health, which in turn posted them on its website. In
addition, RCW 70.170.060 and WAC 246-453-070 requires hospitals to submit charity care
policies, procedures and sliding fee schedules to the department for review and approval.
Harrison has complied with this requirement as well. The policies posted on the DOH website
are:
The posted policies represent the current policies of Harrison. We do not believe that any
changes are required. Should the Program want to see any changes, we understand that it has
placed conditions on CNs in the past with the requirement that the applicant provide any updated
policies prior to initiating the CN approved project. In the highly unlikely event that the
Program finds it would like a revision, Harrison would be happy to comply with such
requirement.
2
DOH website indicates that this was updated November 2012; document itself indicates it was updated 6/20/2014.
8
Under financial feasibility, Field cites an October article in Modern Healthcare and alludes that
CHI is facing some financial struggles, and is contemplating merger. For this reason, she
suggests that the project should not be approved. Most large systems today regularly assess the
market and contemplate mergers, affiliations or acquisitions. CHI is no different.
As noted in our application, CHI Franciscan, together with CHI, have elected to use a
combination of its reserves and debt ($145 million) for the financing of this project. The entirety
of Phase 1 will be funded through reserves. Phase 2 includes both reserves and debt.
Attachment 2 of our screening response included a letter from CHIs Senior Vice President,
Corporate Finance and Investments confirming these facts.
In the event that CHI acquired or merged with another entity prior to the completion of the
Harrison project, we would notify the Program of this fact. Consistent with WAC 246-310-500,
if the Program determined that such upstream affiliation affected the CN approved project, we
are well aware that we would need to either document substantial completion or submit a new
CN application.
Under Cost Containment, Field states that the costs for Phase two are higher than for the Phase 1.
This is true, and was explained in our application: Phase 2 requires the construction of a second
tower. As such, additional costs related to the site are being incurred. At this point, the Field
report states that the Department may accept the argument that a hospital can keep and relocate
un-used licensed beds, it must also determine that spending patient care dollars to rebuild those
beds is cost-effective and the preferred alternative. Harrison has conducted its due diligence,
and Harrison and CHI have retained numerous outside experts to evaluate construction options
and to value engineer the project. Value engineering is an integral part the design stage of a new
development. Its purpose is to increase value (defined as function divided by cost). Neither CHI
nor Harrison would proceed with a project that is not bringing value to the Kitsap Peninsula.
The Catholics for Choice letter and the largely unsigned letter dated February 21, 2017 from a
number of organizations including the ACLU and Planned Parenthood suggest that Harrison fails
to meet the health care needs of the community. The letters make quite a few statements with
absolutely no substantiation (no patient stories, no patient complaints, etc.). Again, Harrison is
not aware of any patients that were denied service or experienced access problems. We are a
secular organization and open and accessible to all patients.
9
Concern #2: A handful of physicians, each of which is affiliated with an existing
health care facility expressed concern about the utilization of their
respective facilities. The operation of these facilities is not impacted
by the Harrison CN application and several of the statements they
made are either inaccurate, or we are not able to substantiate them.
By Harrisons review, four physicians wrote letters in opposition to the project. The physicians
and their respective affiliations are outlined in Table 1.
Table 1
Affiliation of Providers Opposing the Harrison Consolidation
Provider Type of
Specialty Affiliation Unsubstantiated Comments
Name Facility
Physician
Manfred Market position, increased costs,
InHealth owned
Henne, MD, Radiology inflating physician salaries,
Imaging imaging
Poulsbo closed EHR
center
Kitsap Impact of hospital consolidation
Paul
Podiatry on ASC use
Aufderheide, Clinic and
Podiatry Foot and CHI alleged practice of
DPM, ASC
Ankle prohibiting or discouraging
Bremerton
Specialists physicians from using ASCs.
An expenditure of this
magnitude will put pressure on
the hospital to keep its beds and
Peninsula
Berit Madsen, Radiation Radiation other facilities full and further
Cancer
MD, Poulsbo Oncologist Oncology restrict referrals to non-hospital
Center
outpatient facilities that can
deliver services at a fraction of
the cost
Carol
Surgery
Cassella, MD,
Anesthesiologist Center of ASC Monopoly, costs, Catholic system
Bainbridge
Silverdale
Island
10
Each of the providers noted above is a quality provider that serves Kitsap residents. Each of
these providers is also affiliated with a health care facility, and therefore has, to at least some
degree, a conflict of interest. While several raised concerns about costs, no data was provided
for us to refute 3. The fact is that Franciscan is very interested in lower cost options. We
established one of the first Accountable Care organizations in Washington State, now known
as the Rainier Health Network. As the Program is aware, CMS established accountable care
organization (ACO) models to promote care coordination and lower costs. The Medicare
Shared Savings Program (MSSP) rewards ACOs that achieve better care for patients while
keeping costs low. Success is measured by the programs 33 quality measures in four main
areas:
1) Patient/caregiver experience
2) Preventive health
4) At-risk population
To achieve these outcomes, we actively seek out physician partners and every opportunity to
lower costs. A listing of our physician ACO partners is included in Appendix 2. In addition,
CHI, CHI Franciscan and Harrison all abide by all federal regulations at all times. We take the
unsubstantiated comments about inflating physician salaries and creating a monopoly seriously.
We have not inflated salaries nor do we utilize any monopolistic practices.
3
Dr. Cassella referenced up to $500 lab tests and $5,000 orthopedic surgeries. We cannot substantiate these
statements, and neither did Dr. Cassella.
11
Concern #3: The City of Bremertons request to require Harrison to maintain beds
in Bremerton places the entire project at risk.
Harrison enjoys a long, positive partnership with the City, and we also share a mission of service
to local residents. We respectfully, but wholly disagree with the Citys conclusion that the
relocation and consolidation of Harrison will reduce access to acute care beds and medical
services for the portion of Kitsap County residents that live in the greater Bremerton area. The
Citys position seems predicated on its statement that if the certificate of need is approved,
Harrison will relocate medical care services from a high need area to a lower need area. The
City fails to acknowledge that Harrison intends to construct a new, large Ambulatory Care
Center (ACC) in Bremerton that will include primary care, urgent care, and ancillary services. It
will also be home to our new Family Practice Residency Program that will ultimately include 24
residents. The new ACC will be the largest primary care center in the entirety of Kitsap County.
In addition, the new location will be the demonstration location for Harrisons integration of
mental health into primary care, thereby offering earlier behavioral health intervention that
supports decreased crisis and hospitalization.
Harrison concurs that the City of Bremerton has lower income and more poverty than many
other areas of Kitsap County. Working with Kitsap Public Health District and others on this
project has allowed us to confidently conclude that the new ACC, along with a more efficient
and consolidated hospital is in the best interests of City of Bremerton residents.
The City also misquotes the cost of bringing the Bremerton facility to standards that would allow
us to maintain current operations. On page 1 of its letter, the City states the cost is $130 million.
In fact, and as noted in our CN application, the cost is more than $212 million:
The City also fails to note that the more than $9 million in annual savings associated with
consolidation, will be available for reinvestment into programs and services that benefit all
Kitsap residents.
If Harrison is conditioned to leave beds in Bremerton, the entire project is placed at risk. We
will need to expend considerably more funds to keep any inpatient capacity in Bremerton.
Further, the efficiencies expected will not be realized.
12
Conclusion
In conclusion, as noted throughout our application and this document, CHI Franciscans proposal
to consolidate acute care services in Silverdale will improve and enhance the patient care
environment. No change in services is proposed with the acute care consolidation.
Many of the concerns raised were related to Catholic Ethical and Religious Directives. As
stated throughout the public hearing and this document, Harrison is secular and operates in
full conformance with its womens reproductive services and end of life care policies as
posted on the Department of Healths website. Harrisons nondiscrimination policy, which
has also been approved by the Department of Health, precludes discrimination. These
Policies are very clear: all persons who need immediate medical care will receive it, with no
conditions and no screening. At Harrison, medical necessity drives care, not race, color,
religion, sex, national origin, age, disability, citizenship, sexual orientation, gender identity,
genetic information, marital status, veteran status, or other protected status.
While concerns were raised regarding UGHs discontinuation of obstetric and gynecology
services, including pregnancy termination, elective sterilization services, and end of life
services consistent with the Death with Dignity Act, both PeaceHealth and UGH state
that these services are not currently offered at UGH. This assertion is substantiated in the
application and a review of historical CHARS data reported to the Department of Health
by UGH. [source: Application, p15 and 2009 2011 CHARS data]
Current policies and procedures in use at UGH demonstrate that UGH does not currently
discriminate based on gender or sexual preference. Current PeaceHealth policies and
procedures used at St. Joseph Medical Center demonstrate that non-discriminate access to
care at UGH would continue under the PeaceHealth lease.
In summary, WAC 246-310-210(1)(a) does not apply in this project because there is no
elimination of services at UGH. Residents of the planning area would continue to have
access to the same services currently provided at UGH under the PeaceHealth lease.
Based on the source information reviewed and compliance of the conditions regarding the
Admissions Procedure and Patients Right and Responsibilities Policy and the percentage
of charity care to be provided at PHUGH, this sub-criterion is met.
4
Evaluation dated May 20, 2013, for the Certificate of Need application submitted by PeaceHealth proposing to
lease and operate Skagit County Public Hospital District #304 dba United General Hospital located in Skagit
County, pg. 10-11.
13
As with United General, this Harrison application proposes absolutely no change in
services. In fact, approval of this application will provide Kitsap county residents with a
state of the art, efficient facility in which to receive care. The new facility will allow
Harrison to offer evidence based care environments that support optimal healing, enhance the
patient care experience, reduce infections risks, and increase clinical efficiencies. And, most
importantly, result in increased patient satisfaction.
Therefore, we respectfully request the Program approve our request to relocate the acute
care beds at Harrisons Bremerton campus to Silverdale.
14
Appendix 1
Medical Practice Insider Article
15
16
Appendix 2
Physician ACO Partner List
17
Adult And Geriatric Medicine PLLC NW Pain Management And
Allcare Medical Clinic Inc. Rehabilitation Associates, Inc
Bonney Lake Medical Center Nw Regional Hospital For
Bridgeport Medical Clinic, PLLC Respiratory & Complex Care
Burien Digestive Health Center LLC Pace Dermatology Associates PLLC
Cascade Eye & Skin Centers, PC Pacific Cardiovascular DPM, PS
Center For Women's Health PC Pacific Podiatry Group, PS
Christian Family Care, Inc Peninsula Family Medical Center
Clearview Eye and Laser PLLC Portland Avenue Family Clinic Inc
Comprehensive Sleep Medicine Inc Primary Care Northwest PLLC
PS Proliance Surgeons, Inc, PS
Digestive Health Specialists PS Puget Sound Allergy Asthma &
Doctors Clinic A Professional Immunology
Corporation Puyallup Dermatology Clinic Inc
Ear Nose Throat And Allergy P.S.
Associates Rainier Nephrology, PLLC
Electrodiagnosis & Rehabilitation Retina Institute, PLLC
Associates Of Tacoma PS Saint Clare Hospital
Enumclaw Regional Hospital Seatac Primary Care Physicians, Inc.
Association Skin Cancer Clinic Of Seattle Inc PS
Eye Mds Of Puget Sound PLLC Sound Clinical Medicine, P.S.
FHS Inpatient Team South Puget Sound Neurology PLLC
Foot And Ankle Specialists PLLC South Seattle Nephrology Associates
Franciscan Health System* Southwest Portland Medical Clinic,
Franciscan Medical Group Inc.
Hanmi Medical Clinic LLC St Francis Community Hospital
Harrison Medical Center* Summit View Clinic, Inc., P.S.
Highline Internal Medicine PS Sumner Family Eyecare, PLLC
Highline Medical Center* Surgical Associates Northwest, P.C.
Home Towne Family Medicine, Synergy Health
PLLC Tacoma Radiation Center Inc
Hudson's Bay Medical Group Tanya Wilke Family Medicine
Integrated Neurology Health TLC Physicians PLLC
Services, PS WASEA Medical LLC
Key Medical Center, PLLC Adam Nickel, MD ^
My Family Doctor LLC Amos Shirman, MD ^
North Kitsap Family Practice And Barry Bockow, MD PS
Urgent Care PS Christen Vu, MD
Northwest Family & Spinal Clinic Curtis Burnett MD ^
Inc PS Cynthia Taylor, MD ^
Northwest Medical Specialties PLLC D Loomis, MD ^
Northwest Physicians Medical Daniel Gottlieb, MD ^
Group, PLLC Daniel Ziperovich, MD ^
Northwest Vein And Aesthetic David C Reed MD PLLC ^
Center PS David L Lukens, DO PS ^
18
Dennis N Gusman, MD ^ Max Lee, MD ^
Edward W. Hartzler, MD, Inc, PS ^ Michael E Blatner MD PS ^
George Ankuta, MD ^ Michael Steiner, MD ^
Hsushi Yeh, MD Paul Andrew Sueno MD PLLC ^
James Graber, MD ^ Philip Vance, MD ^
James M Komorous MD PS R Skoglund MD, PLLC ^
Jeanne Isaacson, M.D., PC ^ Razan R Al-Kudsi, MD ^
Jeffrey Frankel, MD ^ Rena Wong, MD
Jeffrey L Evans, MD PLLC ^ Robert C Wright MD PS ^
Jonathan Y Jin, MD ^ Robert K Chow MD PS ^
Judith Marsden, MD ^ Sarah Neitzel DPM PLLC ^
Kenneth L P Morton Md PC Sheldon J Cowen MD, PS
Kevin Kennedy, MD ^ Stephen Haggard, DPM ^
Lisa Cowden, MD ^ Steve Feller, MD ^
Mark Alenick, MD ^ Steven Mcclean, MD PC ^
19
City of Bremerton
REBUTTAL COMMENTS TO TESTIMONY AND COMMENTS
RECEIVED BY FEBRUARY 21, 2017
CN Application #17 09 dated October 28, 2016
CHI Franciscan Harrison Medical Center Relocation Project
March 15, 2017
The City of Bremerton (City) submits the following rebuttal comments to the testimony and
written comments received regarding CN Application 17 09. CHI Franciscan Harrison Medical
Center (Harrison) proposes to relocate 242 of the 253 acute care beds from their Bremerton
campus to their Silverdale campus at a total cost of $484 million. Upon project completion in
2023, Harrison Medical Center would be licensed for a total 336 acute care beds in Silverdale
and no inpatient beds would remain in Bremerton.
At the public hearing on February 21, 2017, Mayor Patty Lent and representatives of the
Bremerton City Council testified that the City of Bremerton has responsibility, at a minimum,
for emergency services provided through the fire and police departments. Such services
include maintaining the emergency medical transport system to provide stabilization,
treatment, and transportation of patients to hospitals, as well as police detention and transfer
of patients for psychiatric evaluation to hospital emergency rooms. The City of Bremerton
requested and should be granted affected party status because our responsibilities constitute
direct health care services.
We affirm the testimony that we provided at the public hearing, found at pages 211 219 on
the CD of Written Comments. To keep our comments brief, we are incorporating into our
rebuttal testimony the 6-page, unattributed CON issues paper, labeled Comparison of
CHI/Harrison CON Application with Department of Health Review Criteria found at pages 13
19 on the CD of Written Comments. We agree that the Harrison project fails to meet one or
more requirements under each of the four categories of the CON review criteria. We request
that the Department of Health deny the project a Certificate of Need.
At the outset, we wish to express our appreciation to the governing body and management of
CHI Franciscan Harrison Medical Center for their past and current efforts and their desire to
serve the residents of Kitsap County and adjacent counties. On behalf of the 40,000 residents in
our city limits and the 45,000 residents in the metropolitan area surrounding Bremerton, we
object to the realization of Harrisons vision at the expense of our residents safety, security,
and access to a full range of medical care services. The residents of the largest city in Kitsap
County will be adversely affected if Harrisons relocation project is approved as submitted.
A. Unresolved Pivotal Issue Harrison failed to meet the criteria in WAC 246-310-240,
section (1) which states, Superior alternatives, in terms of cost, efficiency, or
effectiveness, are not available or practicable.
Harrison did not consider an alternative to Phase 2 of their proposed project that is superior to
their proposal, in terms of cost and accessibility. In Phase 2, Harrison proposes to build a 74-
bed tower in Silverdale for $201 million. The City asserts that Harrison could build a new 74-bed
hospital on a new site in Bremerton for approximately $115 million. To prove our point, we
offer the example of St. Anthony Hospital in Gig Harbor, an 80-bed, 68,000 sq. ft. general
hospital with a Level IV trauma center which was built in 2009 at a cost of $94 million. Saint
Anthony was built by CHI Franciscan to accommodate the residents of Gig Harbor who
preferred not to travel 12.6 miles to St. Joseph Medical Center in Tacoma. Given that Silverdale
is 10.6 miles from Bremerton, the City of Bremerton requests that our residents be given the
same level of safety, accessibility and convenience as that afforded the residents of Gig Harbor.
B. Impact of the proposed CHI Franciscan Harrison Medical Center project on the
availability and accessibility of inpatient and outpatient services as well as availability
and accessibility of a sufficient supply of physicians in the Bremerton metro area.
Harrison did not select the most cost effective alternative for providing hospital services in
Kitsap County. David Schultz, President of Harrison Medical Center, stated that Harrisons goal
has been to consolidate beds and decant Bremerton for nearly two decades.1 In this single-
minded approach, Harrison elected to expend $484 million in a 2-phase project. The first
phase, costing $283 million, would relocate 168 beds to Silverdale and provide ancillary services
to support a total of 262 acute care beds. We assert that 262 beds are the maximum amount
that Harrison needs in Silverdale. As presented in the public testimony, Harrison is currently
operating 247 beds and can demonstrate a need for only 236 252 beds.2 Our previous
testimony and testimony by Harrison indicates that the 262 beds in Phase 1 could be rebuilt at
the existing campus in Bremerton for $130 $200 million.3
Phase 2, a 74-bed tower with a project cost of $201 million, is not needed at any time
throughout the planning horizon and amounts to bed-banking. The proposal cannot be
construed as being a relocation of an existing hospital that currently operates 247 beds on two
sites.4 The only way that these beds could be approved as part of a relocation project would be
to maintain the two-hospital current status by either incorporating the 74 beds into a
renovation of the current Bremerton campus or building a new 74-bed hospital in Bremerton;
otherwise, the project should be treated as a new hospital facility project subject to the bed
need methodology. In the two-hospital scenario, the occupancy factor applied to the Silverdale
site would be 70% - 75% and to the Bremerton site would be 65%. The more complex, but
lower cost of two-hospital approach included in our testimony would dictate a 10 15-year
timeline rather than an 8-year timeline and thus a higher bed need. As testified to by Harrison,
the increased operating cost associated with the two-hospital model is only $9 million per year,
1
CN Application #17 09 CHI Franciscan Harrison Medical Center Project Rebuttal Comments to
Testimony and Comments Received as of February 21, 2017, Pg. 190
2
Ibid. Pages 13 - 18
3
Ibid. Pages 190, 212
4
Ibid. Page 18
2% of operating costs, an amount which would be offset by a dramatic reduction in capital costs
for renovating or building a smaller hospital in Bremerton.5
Harrison asserts that the Silverdale location will be more accessible than Bremerton for all
residents in the county. Based solely on geography, this assertion is true. What Harrison fails to
consider is the distribution of population throughout the county. The greatest concentration of
population is the 85,000 residents of the Bremerton metropolitan area. For those 85,000
people, the hospital and doctors will be less accessible when Harrison moves to Silverdale.
Silverdale may be accessible to many, but it is convenient for few.
C. Relocating all emergency room services from Bremerton to Silverdale will increase
transport times and the costs associated with ambulance crews, equipment,
equipment maintenance, and fuel for the Bremerton Fire Department.
For Emergency Medical Transport (EMT) alone, the City of Bremerton estimates that the cost
impact of transporting patients to Silverdale instead of Bremerton will be $119,133 per year.
See the attachment. In addition, the ambulance crews will be out-of-service for an additional
10-15 minutes per round trip while they return from Silverdale to the Bremerton city limits. The
estimated cost impact for the Bremerton Police Department is expected to be less than that for
the fire department.
At the hearing, Mr. David Schulz, President of Harrison Medical Center stated that the
demolition costs of $3 million to $5 million for the existing campus are not included in the
relocation project budget. The City requests that the $3 million to $5 million budget for
demolition and green fielding should be included as a condition to the certificate of need. The
Harrison testimony clearly assumes that the building is intended to remain vacant until a new
owner is secured. The Department must place a condition on Harrison that if it abandons the
Bremerton facility that it will restore the site to green field status on a timely basis should a
new owner not emerge.6
E. Based on the public hearing record, there is very little community support for the
Harrison relocation project among non-professionals.
5
Ibid. Page 190, 211
6
Op cit. Pages 191 - 212
management staff, 2 came from relatives of the management staff, 4 came from members of
the medical staff, and 5 came from professionals representing the following organizations:
Central Kitsap Fire & Rescue, Silverdale Water District, Kitsap County Commission, Kitsap
Economic Development Alliance, and the Kitsap Public Health District. None of the 33 favorable
written comments came from ordinary citizens. Besides the five professionals from unrelated
organizations, the only people who support the Harrison project are the professionals who are
governing it, managing it, or practicing medicine.
By contrast, of the 30 written comments that were opposed, 0 came from current or past
members of the Harrison governing body, 0 came from current or past members of the
management staff, 0 came from relatives of the management staff, 4 came from members of
the medical staff, and 6 came from professionals representing the following organizations: CON
Consultant, ACLU, Catholics. 20 of the unfavorable comments came from ordinary people.
Conclusion: An examination of the testimony shows that Harrison has failed to meet the criteria
for the approval of their proposed bed relocation. The City of Bremerton requests that the
Secretary of the Department of Health deny the certificate of need.
City of Bremerton
Bremerton Fire Department
Emergency Medical Transportation
ESTIMATED ANNUAL COST IMPACT OF HARRISON MOVING TO SILVERDALE
as of March 14, 2017
Annual Cost
Extra Cost Description Annual Cost Calculation
$58,524 Labor 467 extra EMT hours @ $62.66/ hour wages & benefits per EMT x 2 EMT's
$31,969 Equipment $176,870 purchase price with a 100,000 mile life = $1.77 per mile x 18,075 extra miles
$21,330 Maintenance $9,306 annual maintenance cost per vehicle / 7,886 miles = $1.18 per mile x 18,075 extra miles
$7,310 Fuel 18,075 extra miles / 6.8 MPG = 2,655 extra gallons of fuel x $2.75 per gallon
$119,133 Total
Nevertheless,
the
374
beds
in
the
current
Harrison
license
have
been
granted
to
a
substantially
different
organization
under
substantially
different
circumstances.
From
the
standpoint
of
Cost
Containment,
Harrison
has
not
provided
a
rationale
for
its
project.
Harrison
has
projected
69,000
patient
days
to
year
2020.
It
is
prohibited
in
its
rebuttal
comments
from
changing
the
rationale
for
this
project
unless
it
proposes
to
amend
its
application.
The
community
owed
a
legitimate
calculation
of
the
need
for
beds
that
will
cost
over
$2.7
million
each
and
where
Harrison
and
its
CHI
affiliated
hospitals
are
among
the
most
expensive
in
the
state.
(See
Attached
graph.).
If
it
cannot
readily
determine
the
need
for
84-100
of
the
beds
are
not
needed,
it
should
require
Harrison
to
re-submit
its
application
and
provide
a
supporting
rationale.
The
Department
must
determine
that
is
approving
the
most
cost
effective
and
appropriate
alternative.
Beyond
the
lack
of
rationale
for
the
projects
bed
capacity
and
capital
expense,
there
are
substantial
issues
that
suggest
the
50
bed
CON
transfer
from
Harrison
to
Harrison/FHS
was
an
error
and,
notwithstanding
its
approval,
is
no
longer
valid
under
the
terms
agreed
upon
by
the
parties:
The
transfer
of
CN
1463
for
50
beds
to
the
combination
of
Harrison
and
FHS
required
continued
adherence
to
the
Non-Discrimination
Policy,
the
End
of
Life
Policy,
the
Patient
Rights
and
Responsibilities
Policy,
as
provided
by
Harrison
and
in
place
before
the
acquisition
by
FHS.
In
fact,
the
Departments
evaluation
of
proposed
transfer
states:
In
this
transfer
application,
the
co-applicants
assert
that
the
affiliation
between
FHS
and
HMC
resulted
in
no
other
changes
in
the
project.
In
light
of
public
comments
by
ACLU
et
al,
Barry
Peter,
the
Departments
conditions
placed
on
the
transfer
are
clearly
no
longer
being
met.
Additionally,
where
Harrisons
current
policies
may
not
have
changed,
it
has
nevertheless
handicapped
its
employees,
physicians
and
other
contractors
from
effectively
carrying
out
those
policies
through
requirements
that
they
adhere
to
the
Catholic
ERDs.
This
makes
it
clear
that
the
policies
reviewed
and
accepted
by
the
Department
at
the
time
of
review
can
no
longer
be
relied
on
to
be
carried
out
at
Harrison
on
a
consistent,
predictable
or
reliable
basis.
The
transfer
of
CN
1463
and
1463A
should
no
longer
be
considered
valid.
In
interpreting
the
applicants
request
to
transfer
Harrisons
CN
from
Harrison
to
the
combination
of
Harrison
and
FHS,
the
Department
did
not
apply
any
standard
as
required
at
WAC
246-310-
200(2)(b)
s.
To
quote
the
findings:
The
applicants
did
not
demonstrate
the
transfer
was
substantially
complete.
Rather,
the
decision
was
based
on
a
dictionary
definition
of
substantial
and
that
cannot
be
interpreted
as
a
standard
definition
of
substantially
complete
The
Department
must
reduce
the
Harrison
license
accordingly,
A
review
of
the
record
will
show
that
CON
evaluations
and
bed
approvals
at
Silverdale
relied
on
lower
standard
occupancy
rates
than
would
be
applied
to
a
one-campus
hospital
of
larger
bed
capacity.
Combining
two
smaller
hospitals
for
which
at
least
one
was
granted
a
greater
number
of
beds
due
to
lower
occupancy
standards
results
in
a
bonus
number
of
licensed
beds
that
could
not
have
been
otherwise
justified.
The
basis
for
these
extra
licensed
number
of
beds
no
longer
exists.
The
Department
must
reduce
the
Harrison
license
accordingly.
The
current
licensed
bed
number
is
different
than
the
current
number
of
set
up
beds.
Harrisons
application
neglected
to
answer
the
question:
how
many
beds
are
set
up?
In
its
financial
documents,
Harrison
is
described
as
having
260
beds.
The
number
of
set
up
beds
reported
to
DOH
is
247.
A
walk
through
the
Bremerton
facility
by
Department
staff
will
show
that
many
of
the
licensed
beds
no
longer
exist
and
could
not
be
set
up
in
24
hours
or
at
all.
The
374-bed
license
has
been
accumulated
using
lower
occupancy
standards
applied
to
a
separate
smaller
facility
at
Silverdale.
Since
all
beds
are
proposed
for
one
location,
the
rationale
for
those
extra
beds
no
longer
exists
and
they
cannot
be
relocated
and
consolidated
into
one
combined
facility
without
a
technical
analysis
of
the
need
for
them.
2.
The
project
as
proposed
will
have
a
serious
and
detrimental
impact
on
small
public
district
hospitals
in
Clallam
and
Jefferson
Counties
At
the
public
hearing
and
in
written
comments,
supporters
of
a
336-bed
hospital
at
Silverdale
celebrated
the
opportunity
for
Harrison
to
more
easily
serve
the
residents
of
Clallam
and
Jefferson
Counties.
However,
a
review
the
application
materials
shows
no
evidence
of
any
joint
planning
or
any
collaborative
discussions
with
the
two
public
hospital
districts
whose
residents
it
has
unilaterally
decided
to
serve.
And,
certainly,
with
84-100
beds
that
are
not
supported
by
its
Harrisons
own
Kitsap
patient
day
projections,
Clallam
and
Jefferson
will
look
like
a
needed
source
of
paying
patients
and
a
way
to
pay
for
overbuilding
the
Silverdale
campus.
A
detailed
bed
need
study
will
permit
discussion
of
market
share
assumptions
and
loss
of
patients
and
revenue
by
Jefferson
and
Olympic
Medical
Centers.
These
hospitals
are
faced
with
very
high
Medicare
and
Medicaid
payer
mix
and
substantial
less
commercial
revenue
than
Harrison.
Of
great
concern
is
the
potential
loss
to
FMG
of
the
areas
physicians,
so
many
are
prized
recruits,
appreciated
for
a
willingness
to
come
to
small
rural
communities
to
practice.
Harrison
and
a
billion-dollar
church
entity
ready
to
place
its
own
physicians
near
these
hospitals
could
force
local
Clallam
and
Jefferson
County
physicians
to
join
CHI
as
has
happened
in
other
communities.
There
is
no
reference
to
Jefferson
Medical
Center
or
Olympic
Medical
Center
in
the
application
materials.
Harrison
does
not
mention
either
hospital
when
asked
how
its
project
relates
to
the
rest
of
the
health
care
system.
The
Department
must
evaluate
the
impact
of
a
large
hospital
at
Silverdale
on
two
small
rural
hospitals
whose
geographic
service
areas
are
truncated
by
seaside
locations
so
that
their
service
areas
only
extend
south
in
the
direction
of
Harrisons
surplus
beds?
A
durable
purpose
of
Certificate
of
Need
review
for
this
regions
existing
hospitals
is
its
long-standing
requirement
of
collaborative
and
cooperative
decision-making
between
providers
who
may
otherwise
damage
the
local
system
by
competing
inappropriately.
A
quick
calculation
using
2015
CHARS
data
shows
that
very
small
market
share
increases
by
Harrison
could
cost
Olympic
and
Jefferson
very
large
percentage
losses
in
patients
in
revenue.
A
1%
increase
by
Harrison
could
reduce
Olympic
revenues
by
4%
and
Jeffersons
by
14%.
The
Department
will
not
be
able
to
determine
that
the
Harrison
project
does
not
constitute
an
unnecessary
duplication
of
services.
3. Despite
claims
that
Harrison
is
secular,
it
is
not.
As
a
result,
now
and
in
the
future,
the
availability
of
reproductive
services
and
end
of
life
care
in
Kitsap
County
is
unstable,
unreliable,
and
unpredictable.
In
recent
legal
challenges
of
hospital
pension
plans
calling
themselves
church
plans
under
ERISA,
CHI
proved
to
a
court
that
it
is
a
church
and
that
its
purpose
is
religious
not
medical.
This
is
borne
out
by
the
mission
statement
that
was
in
place
when
it
acquired
Harrison:
Nurture
the
healing
ministry
of
the
church.
Board
members
include
at
least
three
individuals
who
are
also
CHI
Board
members.
Assuming
the
Nominating
Committee
referred
to
during
the
public
hearing
is
controlled
by
CHI
via
this
interlocking
directorate,
then
CHI
is
in
control
of
the
board
membership
and,
as
a
result,
of
its
decisions.
According
to
Harrison
board
member
Jim
Civillas
public
comments,
the
Harrison
board
was
established
for
the
purpose
of
overseeing
womens
reproductive
services.
This
strongly
suggests
the
board
is
not
truly
a
governing
board
with
fiduciary
responsibility.
It
is,
instead,
a
community
advisory
committee
populated
by
CHI
Board
members
and
the
other
community
members
they
select
on
a
self-perpetuating
basis.
The
Department
requires
other
CON
applicants
to
provide
organization
charts
and
lists
of
all
related
entities,
explanations
of
why
no
self-referral
is
taking
place,
descriptions
of
the
relationships
of
unrelated
organizations
that
may
have
some
of
the
same
owners.
Where
is
the
due
diligence
in
this
application?
Since
Benjamin
Franklins
time,
the
hospital
as
an
institution
has
been
compared
to
a
three-legged
stool.
Every
student
of
health
care
administration
has
been
taught
the
hospital
is
made
up
of
three
parts:
board,
administration,
and
physicians.
These
three
components
support
a
platform
of
health
care
delivery
that
balances
community,
business
and
clinical
care
priorities,
ideally
for
the
good
of
the
patient
and
long-term
stability
of
the
organization.
Standards
for
each
of
these
three
hospital
parts
make
up
the
guidance
provided
by
organizations
such
as
JCAHO,
Medicare
Conditions
of
Participation,
and
the
state
laws
addressing
hospital
licensing.
Washingtons
hospital
licensing
law
addresses
not
only
facility
standards
but
these
three
institutional
parts:
Governance,
Administration,
and
Medical
Staff.
Harrison
administrator
and
community
supporters
state
many
times
now
and
in
the
past
that
Harrison
is
a
secular
hospital.
There
are
two
questions
the
CON
review
of
the
project
must
address:
Is
the
hospital
secular
or
not?
Is Harrison secular? This review of the three parts of Harrison as an institution show it is not secular.
David
Schulz,
Harrisons
CEO,
is
a
CHI
employee,
not
a
Harrison
employee.
As
CHIs
executive
responsible
for
administration
of
its
hospitals
and
medical
groups
in
the
Kitsap
peninsula
market,
Schulz
administers
CHIs
religious
St.
Anthony
Hospital
in
Gig
Harbor.
At
the
same
time,
he
administers
Harrison
Hospital
and
calls
it
a
secular
hospital.
As
a
CHI
executive
reporting
to
other
CHI
executives
in
Tacoma,
he
is
subject
to
the
Catholic
Ethical
and
Religious
Directives.
Depending
on
the
version
of
the
contract
he
has
signed,
he
must
follow
the
directives
and/or
he
must
not
cause
any
component
of
CHI
not
to
follow
the
directives.
If,
under
his
employment
agreement,
his
actions
are
always
controlled
by
the
ERDs,
then
how
can
he
oversee
or
administer
clinical
activity
at
Harrison
that
is
not
permitted
under
those
directives?
It
is
not
possible
for
a
person
to
conform
to
the
ERDs
at
all
times
while
employed
by
CHI
while
at
sometimes
he
does
not
while
making
decisions
at
Harrison.
At
best,
it
is
an
unstable
arrangement
and,
for
reasons
explored
below,
could
change,
removing
this
impossible
conflict.i
Part
of
Harrisons
administrative
staff
is
a
group
of
Medical
Directors
as
required
by
state
law.
Many
of
those
medical
directors
have
contracts
including
obligations
regarding
the
Catholic
ERDs.
Some
have
signed
agreements
requiring
they
adhere
to
the
ERDs;
some
have
signed
contracts
obligating
them
not
to
cause
any
CHI
entity
to
veer
from
the
ERDs.
It
appears
that
any
physicians
that
do
not
have
such
obligations
in
their
contracts
will
have
once
they
come
up
for
renewal.
As
part
of
the
administration,
these
medical
directors,
part
of
hospital
administration,
who
have
consented
to
adhere
to
the
ERDs
cannot
be
said
to
be
secular.
The
FHS/Harrison
Board
is
not
secular.
The
local
group
referring
to
itself
as
the
Harrison
board
members
includes
at
least
three
members
who
are
also
CHI
Board
members.
One
must
assume
the
Nominating
Committee
referred
to
during
the
public
hearing
is
controlled
by
CHI
via
this
interlocking
directorate.
This
means
that
CHI
is
in
control
of
the
board
membership
and,
as
a
result,
of
its
decisions.
According
to
Harrison
board
member
Jim
Civillas
public
comments,
the
Harrison
board
was
established,
at
the
time
of
the
CHI
acquisition,
for
the
purpose
of
overseeing
womens
reproductive
services.
We
have
not
seen
the
charge
to
the
board
or
who
sits
on
the
Nominating
Committee.
The
meetings
of
the
board
are
apparently
closed
and
the
minutes
not
made
public.
It
is
most
likely
that
this
board
is
not
truly
a
governing
board
with
fiduciary
responsibility
for
Harrison.
It
is,
instead,
a
community
advisory
board
populated
by
CHI
Board
members
and
the
other
community
members
that
CHI
representatives
select
on
a
self-
perpetuating
basis.
From
public
comment,
we
know
the
board
could
change
the
secular
status
of
the
hospital
at
any
time
to
religious.
We
have
not
heard
its
rationale
for
refusing
to
provide
a
full
range
of
reproductive
and
end
of
life
services.
It
is
hard
to
believe
these
refusals
are
not
based
on
religious
doctrine
whether
directed
by
contract
or
held
by
CHI-selected
members.
Public
comment
by
one
Harrison
board
member
stated
that
the
Harrison
board
agreed
as
part
of
its
acquisition
by
CHI
that
it
would
never
perform
abortions.
We
have
not
seen
the
basis
for
this
refusal
of
a
legal
health
care
procedure
to
the
women
of
Harrisons
service
area.
A
review
of
the
acquisition
agreement,
if
it
were
available,
would
provide
its
religious
basis
as
it
was
made
by
non-physicians
for
other
than
medical
reasons.
The
original
Harrison
board
agreed
to
a
five-year
renewal
period
when
it
was
acquired
by
CHI.
The
only
available
copy
of
the
agreement
is
a
draft
reviewed
during
the
Departments
determination
that
the
acquisition
was
not
reviewable
under
Washington
law.
In
that
draft,
the
section
on
ERDs
includes
a
redaction.
Neither
the
Department
nor
the
public
know
what
Harrison
and
CHI
agreed
to
regarding
the
ERDs.
it
is
safe
to
assume
that
more
complete
adherence
to
the
ERDs
could
be
required
of
the
Harrison
board
when
the
5-year
mark
is
reached
in
2018.
According
to
Harrison
board
member
Jim
Civillas
public
comments,
the
Harrison
board
was
established
for
the
purpose
of
overseeing
womens
reproductive
services.
This
strongly
suggests
the
board
is
not
truly
a
governing
board
with
fiduciary
responsibility.
It
is,
instead,
a
community
advisory
committee
populated
by
CHI
Board
members
and
the
other
community
members
they
select
on
a
self-perpetuating
basis.
Though
one
may
believe
that
Harrison
is
secular
now,
it
is
clear
the
situation
is
not
stable
and
the
Department
is
at
risk
for
approving
a
project
whose
description
could
easily
change
within
a
few
months.:
As
long
as
CHI
controls
the
board
nominating
process,
the
secular
status
of
Harrison
could
be
changed
at
any
time
and
therefore
the
range
of
services
provided
there
can
be
changed
to
more
closely
adhere
to
the
ERDs.
Harrison
board,
if
it
does
exercise
any
control,
can
change
the
secular
status
of
the
hospital
when
it
wants
to.
The
FHS/CHI
website
provides
a
short-term
goal
for
the
Northwest
region
of
One
CHI.
This
suggests
a
short-term
goal
to
pull
affiliated
Harrison
fully
under
the
direct
ownership
of
CHI.
Harrison/CHI
agreement
is
up
for
renewal
at
5
years;
this
is
assumed
to
mean
2018.
The
general
belief
among
many
in
the
Kitsap
medical
community
is
that
Harrison
still
does
tubals
but
only
for
two
more
years.
The
Harrison
medical
staff
and
its
affiliated
medical
groups
are
not
secular.
A
third
of
the
three
legs
of
the
hospital
institution
is
the
medical
staff.
Physicians
across
Kitsap
have
already
signed,
or
will
be
asked
to
sign,
agreements
obligating
them
to
adhere
to
the
ERDs
or
to
avoid
causing
any
CHI
entity
to
veer
away
from
them.
It
is
estimated
that
80%
of
Kitsap
physicians
are
now
obligated
under
ERD
requirements
in
their
contracts.
Please
see
attached
an
example
one
physician
has
in
his
contract.
It
appears
that
Harrison
Partners
and
the
Doctors
Clinic
physicians
are
all
now
being
moved
into
the
Franciscan
Medical
Group,
part
of
Franciscan/CHI.
There
are
many
specialties
serving
Harrison
in
which
every
physician
in
that
specialty
have
now
agreed
to
adhere
to
the
ERDs.
Other
physicians
contracts
include
a
series
of
web
links
that
eventually
reach
the
Catholic
Bishops
web
site
and
a
copy
of
the
ERDs.
The
physician
signing
must
state
he
or
she
has
read
the
string
of
documents
under
the
rubric
of
a
CHI
Code
of
Conduct
but
that
obscurely
and
eventually
links
to
the
ERDs
thus
incorporating
them
into
the
physician
agreement.
The
Harrison
application
did
not
acknowledge
the
CHI/Franciscans
religiously-aligned
hospice
actually
operates
within
Harrison.
With
offices
in
Tacoma,
this
hospice
is
active
across
Kitsap
and,
as
David
Bucher,
Harrisons
Palliative
Care
Director,
stated
at
the
hearing,
this
religious
hospice
is
actively
involved
with
terminally-ill
patients
on
the
nursing
units
in
Harrison.
So,
despite
the
statements
that
the
hospital
is
secular,
we
know
this
religious
hospice
one
that
does
not
appear
to
cooperate
with
Death
with
Dignity
is
providing
direct
services
at
Harrison.
We
do
not
know
if
Kitsap
branch
of
the
CHI/Franciscan
Hospice
has
its
own
medical
director,
but
all
care
offered
by
the
hospice
is;
provided
under
the
direction
of
a
CHI
hospice
medical
director
bound
by
Catholic
doctrine.
Attachments
$70,000
Case
Mix
Adjusted
Charges
by
Case
Mix
$65,000 Washington
Hospitals,
2014
CHARS
$60,000
$55,000
$50,000 Harrison
Case-Mix
Adjusted
Charge
per
Discharge
$45,000
$40,000
$35,000
$30,000
$25,000
$20,000
$15,000
$10,000
$5,000
$0
0.20 0.70 1.20 1.70 2.20
Case
Mix
Index
COMPARISON
OF
CHI/HARRISON
CON
APPLICATION
with
DEPARTMENT
OF
HEALTH
REVIEW
CRITERIA
When
it
reviews
a
Certificate
of
Need,
the
WA
Department
of
Health
applies
4
categories
of
criteria
from
Washington
law:
Need
and
Access;
Financial
Feasibility,
Process
of
Care
(Quality);
and
Cost
Containment.
Where
the
Department
finds
that
the
information
the
applicant
provided
does
not
conform
to
the
criteria,
it
must
deny
the
application.
When
it
finds
the
applicant
has
not
provided
sufficient
information
to
make
a
determination,
it
must
deny
the
project
or
declare
a
Pivotal
Unresolved
Issue
(PUI)
and
collect
additional
information
and
hold
a
second
public
hearing.
NEED
AND
ACCESS
CRITERIA
CHI/Harrison
has
247
set-up
beds
today
and
a
license
of
347.
It
proposes
a
project
that
will
result
in
336
beds
and
eliminates
11
psychiatric
beds.
It
must
provide
a
rationale
for
its
project
that
will
result
in
up
to
100
more
beds
than
it
will
need
and
eliminates
11
psychiatric
beds.
Assess
the
impact
of
a
new
medical
center
on
the
health
care
system
Today,
CHI/Harrison
has
not
provided
an
assessment
of
the
impact
of
its
closure
on
Bremerton
or
its
creation
of
a
300-bed
hospital
in
a
new
location.
In
contrast
to
the
quiet
creation
of
the
Silverdale
branch
of
CHI/Harrison,
this
project
proposes
establishing
a
major
medical
center
in
an
entirely
different
community.
The
Department
must
require
such
an
assessment
because
the
volumes
projected
to
2025
do
not
support
the
proposed
336
beds.
The
table
below
shows
the
number
of
excess
beds
in
the
project,
assuming
two
different
occupancy
rates,
80%
or
75%.
The
table
shows
that
CHI/Harrison
proposes
building
from
84
to
100
more
beds
than
will
be
needed
in
2025,
eight
years
from
the
application
year.
To
project
further
begins
to
treat
the
project
as
a
new
hospital,
not
the
relocation
of
beds
from
one
campus
to
another
by
a
hospital.
Harrison
Bed
Need,
2025
Harrison
Bed
Need
@
Excess
Beds
@
336
Year
Pt
Days
ADC
80%
occ.
75%
occ.
80%
occ
75%
occ.
2020
61,748
169
211
226
125
110
2021
63,167
173
216
231
120
105
2022
64,637
177
221
236
115
100
2023
66,160
181
227
242
109
94
2024
67,739
186
232
247
104
89
2025
69,044
189
236
252
100
84
This
project
locates
the
extra
100
beds
at
substantially
reduced
travel
times
to
Bainbridge
Island
and
to
rural
communities
on
the
Olympic
Peninsula
that
support
two
small
public
district
hospitals.
Many
residents
of
these
areas
fear
being
referred
or
transported
to
an
emergency
room
and
hospital
that
refuses
to
offer
certain
legal
health
care
services
those
residents
may
need
or
want
in
an
emergency
or
at
the
end
of
life.
Utilization
of
these
extra
beds
must
come
from:
The
applicants
response
is
not
complete
since
it
neglects
to
mention
planned
limitations
to
the
services
offered.
Current
limitations
to
services
offered
include
refusals
of
care
that
result
from
the
applicants
adherence
to
religious
directives.
The
Department
cannot
determine
the
projects
conformance
with
the
need
criteria
without
requesting
a
full
response
to
this
question.
Access
to
needed
care
Need
Criteria
include:
the
effect
of
the
reduction,
elimination,
or
relocation
of
the
service
on
the
ability
of
low-income
persons,
racial
and
ethnic
minorities,
women,
handicapped
persons,
and
other
underserved
groups
and
the
elderly
to
obtain
needed
health
care;
2. In the context of the criteria contained in WAC 248-19-370(2) (a) and (2) (b),
document the manner in which:
a. Access of low income persons, racial and ethnic minorities, women and mentally
handicapped persons and other underserved groups to the services proposed is
commensurate with such persons need for the health services (particularly those needs
identified in the applicable Health Systems Plan as deserving of priority). (Note: SHP
General
Performance
Standards
(at
Vol
II,
page
B-1)
include:
All
facilities
and
agencies
providing
health
care
services
shall
have
a
patient
priority
policy
which
requires
acceptance
of
patients
according
to
clinical
evidence
of
medical
need
and
potential
benefit
to
patients.
b. In the case of the relocation of a facility or service, or the reduction or elimination
of a service, the present needs of the defined population for that facility or service,
including the needs of underserved groups, will continue to be met by the proposed
relocation or by alternative arrangements.
Admission to each of CHI Franciscans facilities and programs is based on clinical need.
Services are made available to all persons regardless of race, color, creed, sex, national origin, or
disability.
All needs of the service area residents, including the underserved, will continue to be met.
CHI posted a net loss of $568.1 million in the first nine months of its
fiscal 2016, which began July 1, 2015. Health IT costs, investment
losses and troubles with its health insurance company spearheaded
the massive deficit. CHI's credit rating from Fitch, which covers $6
In
this
context,
it
is
important
to
note
that
the
combination
of
the
proposed
Phases
I
and
II,
along
with
additional
unreviewable
construction,
totals
upwards
of
a
billion
dollars
on
the
Silverdale
campus.
The
public
and
the
Department
are
provided
with
no
basis
on
which
to
evaluate
CHI/Harrison
revenue
or
expense.
None
of
the
line
items
can
be
compared
to
any
other
project
or
standard
so
the
feasibility
of
project
cannot
be
determined.
CHI
finances
have
been
deteriorating
and
it
is
contemplating
merger
with
another
entity
for
which
the
Department
has
no
financial
information.
Accordingly,
the
project
must
not
be
granted
a
Certificate
of
Need.
PROCESS
OF
CARE
(QUALITY)
CRITERIA
WA
licensing
requirement
to
inform
patients
Governor
Inslee
asked
the
Department
of
Health
to
develop
rules
that
more
clearly
allow
it
to
review
changes
of
control
over
WA
hospitals
and
to
assess
the
impact
on
its
community
when
a
hospital
changes
hands.
The
new
rule
was
successfully
challenged
in
court
by
hospitals.
To
date,
the
Department
has
not
announced
a
second
effort
to
address
the
matter.
Surviving
the
courts
decision
was
a
change
to
Washingtons
hospital
licensing
rules
that
clarified
a
licensed
hospitals
responsibility
to
provide
certain
information
to
its
community
and
its
patients.
The
result
was
the
current
version
of
WAC-246-320-141,
entitled
Patient
rights
and
organizational
ethics.
Section
1
of
this
rule
outlines
the
types
of
patient
rights
that
a
hospital
policy
must
address.
Sections
5-8
require
the
policies
in
Section
1
to
address
specific
patient
rights
of
access
and
make
those
policies
available
to
the
public.
These
specific
areas
include
1)
admission,
2)
non-
discrimination,
3)
end
of
life
care
and
4)
reproductive
health
care.
The
rule
does
not
require
that
each
hospital
guarantee
the
same
level
of
access
under
its
published
patients
rights
policies
but
it
does
require
the
information
be
available
to
patients
and
to
the
community.
A
review
of
the
policies
CHI/Harrison
makes
available
does
not
satisfy
the
requirements
of
the
licensing
law.
The
documents
provided
about
CHI/Harrisons
policies
are
too
vague
to
provide
useful
information
to
an
interested
Kitsap
resident.
This
licensing
revision
is
a
very
small
part
left
of
an
effort
to
review
community-wide
impacts
on
hospital
acquisitions.
As
such,
they
require
a
hospital
to
be
more
clear
and
specific
in
the
information
it
provides.
Without
such
information,
a
potential
patient
cannot
weigh
the
risk
of
using
the
CHI/Harrison
emergency
room
or
being
admitted
there
vs.
use
of
an
alternate
hospital
or
form
of
care.
Especially
in
end
of
life
care
and
reproductive
health
care,
urgent
clinical
situations
can
arise.
Such
urgent
or
emergent
situations
will
preclude
a
time-consuming
effort
to
discern
a
hospitals
policy
to
refuse
or
require
care
that
is
specific
to
the
patients
immediate
medical
condition.
Until
CHI/Harrison
provides
more
detail,
Kitsap
residents
cannot
discern
the
effect
of
its
ethical
concerns
and
religious
directives
on
the
care
it
provides.
Officials
of
the
Department
of
Health
must
reconcile
the
fact
of
CHI/Harrisons
license
with
its
clear
lack
of
responsiveness
to
WAC-246-320-
141.
The
Department
of
Health
should
declare
a
Pivotal
Unresolved
Issue
in
this
matter.
CHI/Harrison
should
be
asked
to
fully
complete
a
checklist
such
as
that
provided
at
clearhealthwa.org
in
order
to
meet
its
responsibilities.
Until
it
does
so,
the
Department
must
find
that
the
applicant
does
not
meet
the
requirements
of
WAC
246-310-230,
Criteria
for
structure
and
The applicant proposes to pay for this half-a-billion dollar project through a
combination of its current reserves and debt financing. Presumably, the reserves
and debt will have to be replenished by passing along the cost to Kitsap residents.
If not, can the applicant explain how these funds will be recouped without
burdening our community?
Dr. Griffith Blackmon is an outstanding physician and we have the utmost respect
for him and his colleagues, who deliver superb care to critically ill patients in
Harrisons ICU. But Dr. Blackmon did not specifically address whether he or his
colleagues are allowed to participate in the DWD act allowing medically assisted
death with prescription medications, a service that is lawfully guaranteed to
Kitsap residents as of 2009.
Similarly, Mr. David Veterane, former Chairman of the Board at Harrison stated
that the same reproductive care and end-of-life services that were offered prior to
the affiliation are available today.
Harrisons revised policy after the merger now states: while Harrison was
initially neutral during the DWD campaign, once passed, we adopted a policy of
not participating in the administration of the DWD drugs at any of our sites. This
is consistent with many other hospitals in the state. Up until our affiliation with
FHS, our employed physicians were allowed to write the prescription for the
drugs. This changed Aug 1st, 2013 and HMC employed physicians are no longer
able to write these scripts while on duty as an employed doc. These physicians
can, if they wish and under their WA license, separately see patients and prescribe
the drugs for the DWD. Under these circumstances, these physicians would also
have to obtain separate malpractice insurance. (For a copy of the full email
exchange between Mr. Bosch and Mr. Miller please see Appendage B.)
2
Note that while HMC may claim they still allow employees to prescribe these
drugs if they wish, their refusal to cover these physicians through their existing
Harrison-provided malpractice insurance makes such participation so
professionally risky and unfeasible it is effectively prohibited.
We were reassured to hear Dr. Anita McIntyre say that all reproductive services
are available today, just as were prior to the affiliation, and she understands those
rights will be fully protected by HMC in the future.
At the CON hearing Mr. David Schultz, HMCs current CEO, stated that HMCs
board could overturn Harrisons secular status but the sitting board has promised
not to do so. However, all new board members must be approved by FHV, so the
composition of the board can change such that their views on reproductive
services are restricted by the Ethical and Religious Directives (ERDs) enforced at
other CHI facilities. The affiliation agreement between Harrison and CHI spoke
to such a Board Conversion event, as evidenced by these paragraphs extracted
from the agreement: (For the full text refer to Appendage C.)
The slate of candidates will be submitted to the HMC Board, which shall
review the nominated candidates names and qualifications, and shall vote to
accept or refuse each nominee. The HMC Board shall be required to then
submit to the FHV Board of Directors the slate of approved candidates and
the FHV Board of Directors shall review the names and qualifications of the
submitted candidates, and shall approve or refuse each of the submitted
candidates, provided that approval shall not be unreasonably withheld; if
FHV refuses any nominees submitted by the HMC Board, the HMC Board
shall then within thirty (30) days of any refusal submit to the FHV Board
new candidates for approval for said unfilled positions as set forth earlier in
this Section. Notwithstanding the preceding procedures, if a vacancy exists
on the HMC Board for more than 150 days, FHV may unilaterally fill the
vacancy provided that at all times a super-majority of no less than two-thirds
(23) of the HMC Board consists of persons who live or work within
Jefferson, Kitsap, or Mason Counties.
3
We request that if Harrison is granted this CON they be required to remain secular
and offer all current reproductive rights for a minimum of twenty years.
Appendage B:
Mr. Miller, thank you for contacting me with your questions and concerns. Thru this
process we have discovered that indeed, the policy that you reference is outdated and is
now in the process of being updated. To answer your questions, while Harrison was
initially neutral during the DWD campaign, once passed, we adopted a policy of not
participating in the administration of the DWD drugs at any of our sites. This is
consistent with many other hospitals in the state. Up until our affiliation with FHS, our
employed physicians were allowed to write the prescription for the drugs. This changed
Aug 1st, 2013 and HMC employed physicians are no longer able to write these scripts
while on duty as an employed doc. These physicians can, if they wish and under their
WA license, separately see patients and prescribe the drugs for the DWD. Under these
circumstances, these physicians would also have to obtain separate malpractice insurance.
Harrison continues to have the policy of full disclosure of patient end of life options with
an aggressive palliative care program in place to assist patients and their families in
making these difficult choices. One thing that would be very helpful to our providers
would be to have a comprehensive list of area physicians that we could refer to that do
participate in the DWD act. If you can help us with that, it would be much appreciated. I
hope I have been able to clear up any remaining questions about Harrisons participation
in the DWD process. Please let me know if you have additional ones. Thanks.
We are receiving questions from the community served by Harrison Hospital as well as
the physicians and other medical providers you employ about your policies on the
Washington Death With Dignity Act now that Harrison is affiliated with Franciscan,
which strongly opposes Death With Dignity, prohibits its physicians from participating,
and does not provide helpful information or referrals to patients who make inquiries.
4
Is the policy posted online in your patient handbook
(www.harrisonmedical.org/file_viewer.php?id=5163<http://www.harrisonmedical.org/fil
e_viewer.php?id=5163>) still valid?
If this is not still your policy, could you provide me with your new policy?
Thank you,
5
rmiller@CompassionWA.org<mailto:rmiller@CompassionWA.org>
www.CompassionWA.org<http://www.compassionwa.org/>
Appendage C:
Board Conversion Event shall mean such point in time, if any, in which greater than
thirty percent (30%) of the members of the HMC Board consists of individuals other than
the members of HMC Board on the Closing Date or their replacements nominated by the
HMC Board and approved by FHV pursuant to Section 3.2(c) of this Agreement
(qualified replacements); replacements unilaterally appointed by FHV pursuant to the
last sentence of Section 3.2(c) without a nomination from the HMC Board will not be
deemed qualified replacements;
(c) Vacancies in the HMC Board positions held by the individuals listed in Schedule
3.2(a) or their successors, shall be filled as follows: The HMC Board Nominating
Committee shall, prior to any annual, regular, or special meeting called for the purpose of
electing HMC Board Trustees, and within 120 days after receiving notice of a HMC
Board vacancy, meet and prepare a slate of nominees qualified to serve on the HMC
Board in accordance with the Restated Bylaws. The slate of candidates will be submitted
to the HMC Board, which shall review the nominated candidates names and
qualifications, and shall vote to accept or refuse each nominee. The HMC Board shall be
required to then submit to the FHV Board of Directors the slate of approved candidates
and the FHV Board of Directors shall review the names and qualifications of the
submitted candidates, and shall approve or refuse each of the submitted candidates,
provided that approval shall not be unreasonably withheld; if FHV refuses any nominees
submitted by the HMC Board, the HMC Board shall then within thirty (30) days of any
refusal submit to the FHV Board new candidates for approval for said unfilled positions
as set forth earlier in this Section. Notwithstanding the preceding procedures, if a vacancy
exists on the HMC Board for more than 150 days, FHV may unilaterally fill the vacancy
provided that at all times a super-majority of no less than two-thirds (23) of the HMC
Board consists of persons who live or work within Jefferson, Kitsap, or Mason Counties.
(b) The board of directors of the Oversight Corporation (the Oversight Board) will
consist of not more than five (5) members, one of whom shall be the Chair of the HMC
Board serving as an ex officio member with the right to vote. The initial Oversight Board
shall consist of the individuals set forth on Exhibit I, all of whom will be directors on the
HMC Board. Each subsequent member of the Oversight Board (other than the ex officio
member) shall be appointed by the Oversight Board, shall be directors serving on the
HMC Board or directors who previously served on the HMC Board. All actions of the
Oversight Corporation, including, without limitation, the appointment of Oversight Board
members and the initiation of any legal proceedings pursuant to the Oversight
Agreement, shall require the approval of a majority of the members of the Oversight
Board. The Oversight Corporation and the Oversight Board are required to act only in the
best interests of HMC pursuant to the same fiduciary duties imposed on the HMC Board
6
and directors on the HMC Board.
7
3/11/17
COSTS Associated
with Hospital Monopoliza7on
1
3/11/17
2
3/11/17
50000
40000
30000
20000
10000
0
Hernia repair, inguinal fem Appendectomy Minor small and large bowel Shoulder, Elbow and Forearem
proceudres procedures
200000
150000
Harrison
100000 All WA Hosp with Similar Vol
All WA Hospitals
50000
0
Major Joint Coronary Bypass Cesarean Sec;on Pneumonia
Replacement of
Lower Extremity
3
3/11/17
200000
150000
Harrison
100000 Swedish
Virginia Mason
50000 St. Anthony
0
Major Joint Coronary Bypass Cesarean sec;on Pneumonia
Replacment of lower
extremity
Oct 2014-Sept 2015 data on inpa;ent cost per hospitaliza;on
Source: wahospitalpricing.org (Washington State Hospital Associa;on)
Source: www.cms.gov/Research-Sta;s;cs-Data-and-Systems/sta;s;cs-
trends-and-reports
4
3/11/17
3500
3000
2500 HMC
2000 HMC Pymt
All WA
1500
All WA Pymt
1000
500
0
2011 (163) 2012 (120) 2013 (133) 2014 (162)
5
3/11/17
3500
3000
HMC
2500
HMC Pymts
2000
All WA
1500 All WA Pymts
1000 St Josephs
500
0
2011 (226) 2012 (229) 2013 (312) 2014 (439)
3000
2500
HMC
2000 HMC Pymt
All WA
1500
All WA Pymt
1000 St. Joseph
500
0
2011 (238) 2012 (310) 2013 (157) 2014 (224)
6
3/11/17
300
250
HMC
200
HMC Pymt
150 All WA
50
0
2011 (709) 2012 (847) 2013 (1,290) 2014 (584)
7
3/11/17
2000
HMC
1500
HMC Paymt
All WA
1000
Al WA Pymts
St Joseph's
500
0
2011 (185) 2012 (209) 2013 (220) 2014 (274)
$350.00
$300.00
$250.00 Harrison
$200.00 All WA
HMC Payments
$150.00
St Joseph
$100.00
$50.00
$0.00
2011 (8694) 2012 (10,914) 2013 (12,068) 2014** (13,340)
** in 2014 CMS switched to repor;ng all levels (1-5) of Hospital visits together
8
3/11/17
Some observa7ons
HMC is has signicantly higher charges than average in 7/8 of codes
examined
These charges are increasing over ;me, at a rate of increase higher
than average WA charges
Signicant bumps in charges occurred in 2014 increased rate of
change in 7/8 codes in 2014
Most outlying overcharging is in pa;ent visits
2015 data, not available currently, is essen;al for looking for trends
from merger and monopoliza;on