STATE OF ILLINOIS HEALTH FACILITIES AND SERVICES REVIEW …

STATE OF ILLINOIS

HEALTH FACILITIES AND SERVICES REVIEW BOARD

525 WEST JEFFERSON ST. ? SPRINGFIELD, ILLINOIS 62761 ?(217) 782-3516 FAX: (217) 785-4111

DOCKET ITEM:

BOARD MEETING:

EXEMPTION NUMBER:

C-02

June 4, 2019

#E-016-19

EXEMPTION APPLICANT(S):. Jackson Park Hospital Foundation d/b/a Jackson Park

Hospital and Medical Center

FACILITY NAME and LOCATION: Jackson Park Hospital and Medical Center, Chicago,

Illinois

STATE BOARD STAFF REPORT DISCONTINUATION OF A CATEGORY SERVICE

EXEMPTION REQUEST

I. The Exemption Application

The Applicant (Jackson Park Hospital Foundation d/b/a Jackson Park Hospital and Medical Center) proposes the discontinuation of a 17-bed obstetric category of service. A Safety Net Impact Statement and Charity Care Information have been provided as required. Impact Letters were sent to hospitals within 15-miles of the Jackson Park Hospital that maintain obstetric services. The expected completion date is August 4, 2019.

II. Applicant

Jackson Park Hospital Foundation d/b/a Jackson Park Hospital and Medical Center is a safety net hospital.1 The hospital is located at 7531 South Stony Island Avenue, Chicago,

Illinois in the HSA VI Health Service Area ? Chicago and the A-03 Hospital Planning Area2. The Foundation is in Good Standing with the Illinois Secretary of State and have

provided an attestation of site ownership. The Foundation is accredited by the Joint

Commission.

TABLE ONE Jackson Park Hospital and Medical Center Historical Obstetric Utilization

2017

2016

2015

2014 2013

Obstetric Beds

17

17

17

17

17

Days

529

653

783

897 1,003

Admissions

225

289

332

352

365

ALOS

2.35

2.26

2.36

2.55

2.75

ADC

1.45

1.79

2.15

2.46

2.75

Occupancy

8.53% 10.52% 12.62% 14.46% 16.16%

Births

191

236

281

313

307

Live Births

174

226

273

296

301

III. Applicable Rules

Section 1130.500 - General Requirements for Exemptions

Only those projects specified in Section 1130.410 are eligible for exemption from permit requirements. Persons that have initiated or completed such projects without obtaining an exemption are in

1 Safety Net Determination from Illinois Department of Healthcare and Family Services. 2 A-03 - City of Chicago Community Areas of Douglas, Oakland, Fuller Park, Grand Boulevard, Kenwood, Near South Side, Washington Park, Hyde Park, Woodlawn, South Shore, Chatham, Avalon Park, South Chicago, Burnside, Calumet Heights, Roseland, Pullman, South Deering, East Side, Garfield Ridge, Archer Heights, Brighton Park, New City, West Elsdon, Gage Park, Clearing, West Lawn, West Englewood, Englewood, Chicago Lawn and Greater Grand Crossing.

Page 2 of 8

violation of the provisions of the Act and are subject to the penalties and sanctions of the Act and Section 1130.790. a) Application for Exemption

Any persons proposing a project for an exemption to permit requirements shall submit to HFSRB an application for exemption containing the information required by this Subpart, submit an application fee (if a fee is required), and receive approval from HFSRB. b) General Information Requirements The application for exemption shall include the following information and any additional information specified in this Subpart: 1) the name and address of the applicant or applicants (see Section 1130.220); 2) the name and address of the health care facility; 3) a description of the project, e.g., change of ownership, discontinuation, increase in dialysis

stations; 4) documentation from the Illinois Secretary of State that the applicant is registered to conduct

business in Illinois and is in good standing or, if the applicant is not required to be registered to conduct business in Illinois, evidence of authorization to conduct business in other states; 5) a description of the applicant's organization structure, including a listing of controlling or subsidiary persons; 6) the estimated project cost, including the fair market value of any component and the sources and uses of funds; 7) the anticipated project completion date; 8) verification that the applicant has fulfilled all compliance requirements with all existing permits that have been approved by HFSRB; and 9) the application-processing fee. HFSRB NOTE: If a person or project cannot meet the requirements of exemption, then an application for permit may be filed.

Page 3 of 8

Section 1130.525 - Requirements for Exemptions Involving the Discontinuation of a Health Care Facility or Category of Service

a)

Submission of Application for Exemption

Prior to any person discontinuing a health care facility or category of service, the person shall

submit an application for exemption to the HFSRB, submit the required application-processing fee

(see Section 1130.230), and receive approval from HFSRB.

b)

Application for Exemption

The application for exemption is subject to approval under Section 1130.560 and shall include a

written response addressing the review criteria contained in 77 Ill. Adm. Code 1110.130. The

application shall be available for review on the premises of the health care facility.

c)

Opportunity for Public Hearing

Upon a finding that an application to close a health care facility is complete, the State Board shall

publish a legal notice on 3 consecutive days in a newspaper of general circulation in the area or

community to be affected and afford the public an opportunity to request a hearing. If the application

is for a facility located in a Metropolitan Statistical Area, an additional legal notice shall be

published in a newspaper of limited circulation, if one exists, in the area in which the facility is

located. If the newspaper of limited circulation is published on a daily basis, the additional legal

notice shall be published on 3 consecutive days. The legal notice shall also be posted on the Health

Facilities and Services Review Board's web site and sent to the State Representative and State

Senator of the district in which the health care facility is located. [20 ILCS 3960/8.5(a-3)]

Section 1110.290 - Discontinuation ? Review Criteria

These criteria pertain to the discontinuation of categories of service and health care facilities.

a)

Information Requirements - Review Criterion

The applicant shall provide at least the following information:

1) Identification of the categories of service and the number of beds, if any, that are to be discontinued;

2) Identification of all other clinical services that are to be discontinued;

3) The anticipated date of discontinuation for each identified service or for the entire facility;

4) The anticipated use of the physical plant and equipment after discontinuation occurs;

5) The anticipated disposition and location of all medical records pertaining to the services being discontinued and the length of time the records will be retained;

6)

For applications involving discontinuation of an entire facility, certification by an

authorized representative that all questionnaires and data required by HFSRB or the

Illinois Department of Public Health (IDPH) (e.g., annual questionnaires, capital

expenditures surveys, etc.) will be provided through the date of discontinuation and that

the required information will be submitted no later than 60 days following the date of

discontinuation.

b) Reasons for Discontinuation - Review Criterion

Page 4 of 8

The applicant shall document that the discontinuation is justified by providing data that verifies that one or more of the following factors (and other factors, as applicable) exist with respect to each service being discontinued:

1) Insufficient volume or demand for the service;

2) Lack of sufficient staff to adequately provide the service;

3) The facility or the service is not economically feasible, and continuation impairs the facility's financial viability;

4) The facility or the service is not in compliance with licensing or certification standards.

c)

Impact on Access - Review Criterion

The applicant shall document whether the discontinuation of each service or of the entire facility

will have an adverse impact upon access to care for residents of the facility's market area. The

facility's market area, for purposes of this Section, is the established radii outlined in 77 Ill. Adm.

Code 1100.510(d). Factors that indicate an adverse impact upon access to service for the population

of the facility's market area include, but are not limited to, the following:

1) The service will no longer exist within the established radii outlined in 77 Ill. Adm. Code 1100.510(d) of the applicant facility;

2) Discontinuation of the service will result in creating or increasing a shortage of beds or services, as calculated in the Inventory of Health Care Facilities, which is described in 77 Ill. Adm. Code 1100.70 and found on HFSRB's website;

3) Facilities or a shortage of other categories of service at determined by the provisions of 77 Ill. Adm. Code 1100 or other Sections of this Part.

d) The applicant shall provide copies of notification letters sent to other resources or health care facilities that provide the same services as those proposed for discontinuation and that are located within the established radii outlined in 77 Ill. Adm. Code 1100.510(d). The notification letter must include at least the anticipated date of discontinuation of the service and the total number of patients that received care or

III. State Board Staff Analysis

Jackson Park Hospital and Medical Center proposes to discontinue a 17-bed obstetric category of service including two labor delivery recovery rooms and seven level I and three level II nursery stations/bassinettes. No final plans have made of the use of the vacated space and the equipment will be used in other areas of the hospital, sold or discarded. The medical records will be maintained in accordance with all federal and state legal requirements.

According to the Applicants "The proposed discontinuation is the result low and steadily decreasing obstetrical utilization at the hospital, as identified in the table below. Over past five years (2014-2018), admissions have decreased from 352 to 169, and patient days have decreased from 823 to 430, resulting in a drop in the unit's average daily census from 2.25 patients to 1.18 patients, with the unit being void of patients on a frequent basis."

Page 5 of 8

The Applicant sent impact letters to the 17 hospitals listed below with obstetric services informing those hospitals of Jackson Park Hospital's intent to discontinue obstetric services (See Table Two below). No replies were received from these hospitals by the State Board Staff.

TABLE TWO Hospitals within 15-miles of Jackson Park Hospital and Medical Center with Obstetric Services

Beds, Average Daily Census, & Utilization

Hospital

Safety Net Hospital (1)

Miles (2)

Beds

ADC

Utilization

(3)

Advocate Trinity Hospital

2.9

23

5.405 23.50%

University of Chicago Medical Center

4.6

46

16.514 35.90%

Holy Cross Hospital

Yes

7.6

16

2.432 15.20%

Roseland Community Hospital

Yes

8.3

17

0.306

1.80%

Mercy Hospital & Medical Center

Yes

8.5

30

13.17 43.90%

Little Company of Mary Hospital

9.4

17

8.925 52.50%

St Bernard Hospital

Yes

9.4

22

5.984 27.20%

Northwestern Memorial Hospital

11.2

134

102.51 76.50%

Rnsh University Medical Center

12.3

34

21.794 64.10%

University of Illinois Hospital at Chicago

12.7

45

21.285 47.30%

John H. Stroger, Jr. Hospital of Cook County

12.8

40

17.28 43.20%

St. Anthony Hospital

Yes

13.3

20

10

50.00%

Mount Sinai Hospital Medical Center

Yes

14

30

20.49 68.30%

Saint Mary of Nazareth Hospital

Yes

14.3

20

11.5

57.50%

Advocate Illinois Masonic Medical Center

14.7

44

17.556 39.90%

Saint Joseph Hospital-Chicago

14.7

23

9.453 41.10%

Norwegian-American Hospital

Yes

15

48

6.624 13.80%

1. Safety Net Hospital from Illinois Healthcare and Family Services Determination. (attached to this report)

2. Beds, ADC and Utilization as of December 31, 2017- most recent data available

The Applicants stated: "Jackson Park Hospital and Medical Center ("JPH") is and will continue to be a provider of safety net services to its community. The hospital primarily serves disadvantaged neighborhoods on the south side of Chicago, as reflected in a payer mix that consist of over 50% Medicaid patients, nearly 4% charity care patients, and less than 10% private insurance (inpatients, 2017). Given the low number (169) of patients admitted to the hospital's obstetrics unit in 2018, and with a number of other providers located in close proximity to the hospital, the proposed discontinuation will have minimal impact on accessibility to safety net services. In addition, because of the low number of patients to be impacted, and because it is not anticipated that any single hospital in the area will be the sole provider of obstetrics services to those patients who otherwise would receive their care at JPH, it is not believed that the proposed discontinuation will have a material effect on other hospitals' ability to provide safety net services."

Page 6 of 8

TABLE THREE Jackson Park Hospital and Medical Center

Safety Net Impact Information

Year

2016

2017

2018

Net Revenue

$80,636,255 $81,823,953 $56,878,189

Charity Care

2016

2017

2018

Inpatient

311

265

474

Outpatient

2,638

1,277

3,664

Total

2,949

1,542

4,138

Charity Care

Inpatient

$1,227,492

$1,563,642

$1,592,986

Outpatient

$1,548,081

$1,038,897

$1,956,254

Total

$2,775,573

$2,602,539

$3,549,240

% of Net revenue

3.44%

3.18%

6.24%

Medicaid

Inpatient

3,591

3,867

3,343

Outpatient

24,903

32,742

27,992

Total

28,494

36,609

31,335

Medicaid

Inpatient

$18,498,234 $22,704,787 $15,281,442

Outpatient

$12,545,543 $14,606,116 $10,706,252

Total

$31,043,777 $37,310,903 $25,987,694

% of Net revenue

38.50%

45.60%

45.69%

The Illinois Health Facilities Planning Act (20 ILCS 3960/6) requires that "An exemption shall be approved when information required by the Board by rule is submitted. Projects eligible for an exemption, rather than a permit, include, but are not limited to, change of ownership of a health care facility, discontinuation of a category of service, and discontinuation of a health care facility, other than a health care facility maintained by the State or any agency or department thereof or a nursing home maintained by a county."

The Applicants have provided the required information for this exemption application.

STATE BOARD STAFF FINDS THE PROPOSED PROJECT IN IN CONFORMANCE WITH DISCONTINUATION OF A CATEGORY OF SERVICE OR HEALTH CARE FACILITY (77 ILAC 1130.500, 77 ILAC 1130.520 AND 77 ILAC 1110.290)

Page 7 of 8

Healthcare and Family Services Safety Net Hospital Determination Effective 10/1/2018 - 9/30/2019

89 Illinois Admin Code, Section 149.100(f)(4) provides for a policy adjusment factor of $57.50 per general acute care day for facilities that qualify as a safety-net hospital, as defined in 305 ILCS 5/5-5e.1, excluding pediatric hospitals as defined in 148.25(d)(3).

305 ILCS 5/5-5e.1 Criteria for safety-net hospital status:

A Safety-net hospital is an Illinois hospital hospital that:

(a) Is licensed by the Department of Public Health as a general acute care or pediatric hospital, and: (b) Is a Disproportionate Share hospital, as described in Section 1923 of the federal Social Security Act, as determined by the Department, and:

Meets one of the following criteria:

(c) Has a Medicaid inpatient utilization rate (MIUR) of at least 40% and a charity percent of at least 4%, or: (d) Has a MIUR of at least 50%

(e) Beginning July 1, 2012 and ending on June 30, 2020, a hospital that would have qualified for the rate year beginning October 1, 2011, shall be a Safety-Net Hospital.

Hospital Name

ANN AND ROBERT LURIE CHILDRENS GLENOAKS HOLY CROSS JACKSON PARK LA RABIDA CHILDRENS LORETTO HOSPITAL MERCY-CHICAGO METHODIST-CHICAGO MT SINAI NORWEGIAN-AMERICAN PRESENCE MERCY CENTER-AURORA PRESENCE ST MARY OF NAZARETH ROSELAND COMMUNITY SOUTH SHORE ST ANTHONYS-CHICAGO ST BERNARDS-CHICAGO ST MARYS-CENTRALIA SWEDISH COVENANT THOREK TOUCHETTE REGIONAL HOSPITAL

City

CHICAGO GLENDALE HTS CHICAGO CHICAGO CHICAGO CHICAGO CHICAGO CHICAGO CHICAGO CHICAGO AURORA CHICAGO CHICAGO CHICAGO CHICAGO CHICAGO CENTRALIA CHICAGO CHICAGO EAST ST LOUIS

RY 2019 MIUR

46.24% 42.19% 52.32% 74.81% 87.67% 64.65% 52.00% 65.37% 68.54% 72.38% 45.69% 53.21% 68.30% 46.74% 59.18% 66.40% 36.04% 45.71% 83.87% 66.40%

Charity Percentage

0.16% 2.69% 5.37% 2.67% 0.00% 1.44% 1.87% 1.16% 6.57% 2.98% 2.92% 2.44% 1.60% 1.86% 5.83% 3.35% 0.45% 2.75% 0.45% 3.23%

(a) Safety Net

Hospital on 10/1/2011

Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y

(b) General Acute Care Hospital

Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y

(c) RY19 DSH Hospital

Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y

(d) MIUR >= 40%

and Charity >= 4%

N N Y N N N N N Y N N N N N Y N N N N N

GATEWAY REGIONAL MEDICAL CENTER HARRISBURG HOSPITAL

GRANITE CITY HARRISBURG

50.12%

0.83%

N

Y

Y

N

61.07%

0.42%

N

Y

Y

N

Non-Qualifying, General Acute Care Hospitals

ABRAHAM LINCOLN MEMORIAL

LINCOLN

29.25%

0.97%

N

Y

N

N

ADVENTIST BOLINGBROOK HOSPITAL

BOLLINGBROOK

26.80%

1.43%

N

Y

N

N

ADVENTIST HINSDALE HOSPITAL

HINSDALE

12.03%

0.64%

N

Y

N

N

ADVOCATE BROMENN MEDICAL CTR

BLOOMINGTON

21.46%

0.91%

N

Y

N

N

ADVOCATE CONDELL MEDICAL CENTER

LIBERTYVILLE

27.23%

1.30%

N

Y

N

N

ADVOCATE EUREKA HOSPITAL

EUREKA

10.92%

0.64%

N

Y

N

N

ADVOCATE NORTHSIDE

CHICAGO

37.66%

1.20%

N

Y

Y

N

ADVOCATE SHERMAN HOSPITAL

ELGIN

21.78%

1.39%

N

Y

N

N

ALEXIAN BROTHERS

ELK GROVE VILL

14.85%

1.31%

N

Y

N

N

ALTON MEMORIAL

ALTON

20.98%

0.70%

N

Y

N

N

ANDERSON HOSPITAL

MARYVILLE

19.81%

1.00%

N

Y

N

N

BLESSING HOSPITAL

QUINCY

25.15%

1.93%

N

Y

N

N

CARLE FOUNDATION

URBANA

40.72%

2.44%

N

Y

Y

N

CARLINVILLE AREA HOSPITAL

CARLINVILLE

17.78%

0.00%

N

Y

N

N

CENTRAL DUPAGE

WINFIELD

23.37%

1.73%

N

Y

N

N

CGH MEDICAL CENTER

STERLING

26.23%

0.47%

N

Y

N

N

CHRIST HOSPITAL

OAK LAWN

29.70%

0.83%

N

Y

N

N

CLAY COUNTY

FLORA

24.10%

0.00%

N

Y

N

N

COMMUNITY FIRST MEDICAL CENTER

CHICAGO

33.05%

0.00%

N

Y

N

N

COMMUNITY MEMORIAL-STAUNTON

STAUNTON

18.38%

0.00%

N

Y

N

N

COPLEY MEMORIAL

AURORA

37.81%

0.00%

N

Y

N

N

CRAWFORD MEMORIAL

ROBINSON

29.27%

0.00%

N

Y

N

N

CROSSROADS COMMUNITY

MT VERNON

23.12%

0.26%

N

Y

N

N

DECATUR MEMORIAL

DECATUR

22.55%

0.00%

N

Y

N

N

DELNOR COMMUNITY-GENEVA

GENEVA

13.85%

0.78%

N

Y

N

N

DR. JOHN WARNER

CLINTON

20.18%

0.31%

N

Y

N

N

EDWARD HOSPITAL

NAPERVILLE

7.73%

1.78%

N

Y

N

N

ELMHURST MEMORIAL

ELMHURST

14.15%

1.99%

N

Y

N

N

EVANSTON HOSPITAL

EVANSTON

14.31%

1.51%

N

Y

N

N

F G MCGAW LOYOLA

MAYWOOD

28.87%

0.15%

N

Y

N

N

FAIRFIELD MEMORIAL

FAIRFIELD

20.68%

0.00%

N

Y

N

N

(e) MIUR

>= 50%

N N Y Y Y Y Y Y Y Y N Y Y N Y Y N N Y Y

Y Y

N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N

FFY 19 Safety Net Qualifier

Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y

Y Y

N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N

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