It’s been almost a year since the Georgia Department of Community Health rejected an application from Floyd Medical Center, Tanner Medical Center and Hamilton Medical Center to provide open heart surgery services. All three facilities filed appeals of the decision in July 2018 and it’s been four months since the last appeals hearing was conducted, but still no decision from the state agency.
FMC President and CEO Kurt Stuenkel announced that the hospital was seeking to provide the services in January of 2018 in an electronic notice that was posted on the hospital’s website. Stuenkel pointed out that FMC has a successful cardiology program, which includes a trio of cardiac catheterization labs, angioplasty and implantation of stents and pacemakers. He said the hospital anticipates that it will spend $4.03 million in new construction costs for the heart surgical program.
FMC is seeking to build on those programs in a manner which, in its application claims, “will remedy atypical barriers to care for service area residents based on cost, quality and financial accessibility of current services in the area.”
As you might imagine, Redmond Regional Medical Center filed opposition to the FMC certificate of need. WellStar Kennestone Hospital filed opposition to the Tanner request out of Carrollton.
The barriers which FMC claims exist, again, according to their CON application, include high overall mortality rates from major cardiovascular disease in the service area; low use rates for open heart surgery and high mortality rates from major cardiovascular disease for African American and other race/ethnicity populations in the area; and relative high out-migration of area residents for open heart surgery.
Stuenkel said the high death rate among African Americans is of particular concern and one of the major rationales for FMC seeking the CON.
“Frankly, through the years there has been no outreach to this population,” Stuenkel said.
In its official letter of opposition to the application, Redmond officials said that only in 2016 did Redmond treat African Americans in Floyd County at a lower rate than the state average. It further pointed out that even in that year, African Americans in the five-county service area were treated at a higher rate than the state average, only Floyd County itself fell below the average. Redmond also claimed that in 2017, the rate for African-American treatment at Redmond was tops in the state.
FMC is proposing to add two dedicated open heart surgery operating rooms, an expansion of the prep/recovery and support space and creation of a dedicated cardiovascular post-anesthesia care unit where patients would spend up to 23 hours post-surgery before shifting into a cardiac stepdown/telemetry unit on the fifth floor of the hospital.
The project would call for the construction of a 6,400-square-foot addition to the second floor on the south end of the hospital to house the two new operating rooms and renovation of another 5,450 square feet, also on the second floor.
Total costs associated with the project were estimated, a year and a half ago, at $16,626,368.
FMC believes it meets several criteria for the CON as a safety-net hospital. Among those are that it is a teaching hospital, that it is designated as a trauma center, that Medicaid and Peach Care inpatient admissions make up 20% or more of total inpatient admissions, and that uncompensated charges for indigent patients account for 6% or more of the hospital’s adjusted gross revenue.
Similarly, FMC believes its application is consistent with the goals of the Specialized Cardiovascular Services Component Plan adopted in 2001. The goals of that plan include improving access to cost-effective, quality specialized cardiovascular services, the encouragement of providers to take responsibility for the health of their communities; reflecting the advancing technology and trends in the treatment of cardiovascular disease; encouraging continuity of care for specialized cardiovascular services via the development of comprehensive policies and processes; ensuring quality and patient safety through peer review, performance monitoring and compliance with appropriate standards; improving access to specialized cardiovascular services by mandating the provision of services on a non-discriminatory basis; improving financial access to prevention services; and offering an analysis of he availability and effectiveness of specialized cardiovascular services through the collection and retention of specific data.
The continuity of care argument is significant to FMC because it ultimately would transfer a significant number of patients with heart disease that would lead to the need for open heart surgery. Between Jan. 1, 2017, and Jan. 26, 2018, FMC transferred 64 inpatients to other facilities along with six direct transfers from the FMC cardiac cath lab. FMC argues that those transfers delay and disrupt needed care for those patients.
FMC reported that from 2014 to 2016, its diagnostic cardiac cath procedures increased from 1,432 to 1,747, up 22%, while actual therapeutic cardiac cath procedures were up 45.2% from 376 in 2014 to 546 in 2016.
“Even further, Redmond (Regional Medical Center in Rome) in its obstetrics CON talks about the notion that competition is good. Well, if Redmond believes that for OB, it certainly is true for cardiology services and cardiac surgery,” Stuenkel said. “If Redmond gets OB (which it has been approved for), Floyd should get open heart. Let’s compete on a level playing field.”
Stuenkel said there is going to be a legal challenge to Redmond’s approval to offer OB services through the state court system.
The CON applications filed by FMC, Tanner and Hamilton are part of what is referred to as a batch, and hearings on the appeals of the original denial were held on Dec. 10, 11 and 14 of last year; and Jan. 7-11, Feb. 4-8, Feb. 11-15 and Feb. 26 of this year.
Stuenkel said that in addition to the testimony at the physical hearings, parties were allowed time to submit additional written testimony as part of the appeals process. He said the hearing officer would issue three separate decisions, which is part of the reason the decisions have taken a protracted period of time.
The FMC CEO said each situation is unique but he does not think approval of any of the three open heart CON applications would set any kind of dangerous precedent for expansion of services. He said he suspects that people in need of open heart procedures probably go to Chattanooga.
“Why shouldn’t they have a program when the patients are going out of state?” Stuenkel said. “Similarly, at Tanner Medical Center in Carrollton, I think their rationale is, ‘We send a lot of patients to Atlanta. We think we have the numbers to run a quality program.’ Well why shouldn’t they have consideration for that?”
“We’re expecting some time this summer to get the hearing officer’s ruling,” Stuenkel said.