Peninsula Certificate of Public Need: Questions & Answers
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Peninsula Certificate of Public Need: Questions & Answers 

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What was the Commissioner’s decision regarding the Riverside and Sentara Certificate of Public Need applications?

On February 28, 2007, the State Health Commissioner released the final decision regarding the Certificate of Public Need applications that Sentara filed for additional medical/surgical beds at Sentara CarePlex Hospital, additional medical/surgical beds at Sentara Williamsburg Regional Medical Center, and Riverside Health System’s application to build an acute care hospital in Williamsburg (Doctors’ Hospital of Williamsburg). All applications were filed in Virginia Planning District 21.

The Commissioner’s decision was to approve the Sentara CarePlex Hospital application to add 30 medical/surgical beds, which includes construction of a new wing at the facility, and to deny the Riverside and SWRMC applications for additional medical/surgical capacity in the Williamsburg area.
 
Read the full copy of the Commissioner's decision (PDF file)

What were the reasons for the Commissioner’s approval of additional beds at Sentara CarePlex Hospital?

CarePlex has been an incredible asset to the community and we’re pleased to see that the Commissioner recognized the need for this bed expansion to serve the residents of the Lower Peninsula community. Below are selected reasons State Health Commissioner, Robert Stroube, MD, MPH, gave for his decision (taken directly from text of his decision):

“The proposed project is substantially consistent or in harmony with the SMFP [State Medical Facilities Plan] and its guiding principles.”

“The project would effectively address a clear and growing facility-specific need demonstrated by high acute care utilization at CarePlex Hospital.”

“The project would not have a substantial adverse effect on the utilization, costs and charges of any hospital in PD 21.”

“The project presents a reasonable, incremental means of addressing high utilization of existing acute care resources and attendant operational stresses at Sentara CarePlex Hospital.”

“The high level of utilization of med-surg beds at CarePlex presents direct operational stresses and indicates a compelling facility-specific need for a reasonable addition of such beds – one not likely to be addressed by excess capacity elsewhere.”

“The evidence strongly indicates a public need, expressed as a facility-specific need, for the proposed project. Since its opening in 2002, utilization of inpatient resources at CarePlex has steadily grown. Utilization of the 150 med-surg beds at CarePlex exceeded 85 percent in 2005 and indications exist that it will continue to grow.”

“The proposed project would meet a growing need expressed by the patient population of CarePlex’s existing service area without adverse impact to other providers of acute care services.”


Read the full copy of the Commissioner's decision (PDF file)

What were the reasons for the Commissioner’s denials of the Williamsburg projects?

The guiding principles of the Certificate of Public Need process are intended to ensure that only facilities and services which meet community need and provide for the cost effective delivery of health care are approved. Below are selected reasons State Health Commissioner, Robert Stroube, MD, MPH, gave for his decision (taken directly from text of his decision):

“Since review of COPN Request No. VA-7225, an application that was submitted by Doctors’ Hospital of Williamsburg (wholly owned by Riverside Hospitals, Inc.) on July 1, 2005, and denied on March 13, 2006, no appreciable or otherwise impactful matter has arisen to justify approval of the application proposed by either Riverside or Sentara.”

“Rather than introducing beneficial competition or patient choice, the Doctors’ Hospital of Williamsburg project, at total capital costs exceeding $76 million, presents costly and potentially destabilizing duplication of existing, underutilized acute care resources.”

“The Doctors’ Hospital of Williamsburg project would have a substantial negative affect on the utilization, costs and charges for various services currently provided at SWRMC (which began operations in 2006) and may also negatively affect utilization, costs and charges at other facilities in PD 21.”

“Despite evidence of population growth and aging, some of it conflicting, both projects and especially Doctors’ Hospital of Williamsburg project, present unnecessary costs and duplication of resources that have standing capacity and are currently available to residents in PD 21.”

“Little has changed in the year since Riverside’s first Doctors’ Hospital of Williamsburg project was denied, and the costs associated with the current project proposed by Riverside are considerable, especially in light of the systemic costs associated with the recent construction of SWRMC – a facility designed with area population growth in mind and with the ability to expand to meet projected growth reasonably.”

“Small hospitals, despite Riverside’s evidence to the contrary, typically face challenges of efficiency, quality and general operation. Until reliable data derived by accepted means clearly indicate the need for a number of additional beds roughly equivalent to a reasonably-sized community hospital in upper PD 21, a proposal such as the Doctors’ Hospital project, is at the very least premature under an analysis favorable to Doctors’ Hospital.”

“No public need for a second hospital in upper PD 21 – an area of less than 90,000 residents – exists, despite Riverside’s argument touting population growth, issues of accessibility and future driving times, the supposed need for competition, and expressions of public sentiment.”


The Riverside application included inpatient rehabilitation beds. Those were also denied in the Commissioner’s decision. Sentara has already received State approval for the addition of six inpatient rehab beds at SWRMC. That unit is scheduled to open later this year.


Read the full copy of the Commissioner's decision (PDF file)

Is the process now complete?

The Commissioner’s decision in February effectively concluded the process for the applications that were submitted July 2006. Certificate of Public Need applications for general acute care hospitals and hospital beds can be submitted twice a year – January and July. There is no limit to the number of times an applicant can apply.


Read the full copy of the Commissioner's decision (PDF file)

How can I learn more about Certificate of Public Need?

Certificate of Public Need is a regulatory program present in most states within the U.S. To learn more about the Virginia program, click here.

Read the full copy of the Commissioner's decision (PDF file)




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