April 6, 2021

The Honorable The Honorable Jennifer Campbell, MD Mayor Council President City of City of San Diego 202 C Street, 11th Floor 202 C Street, 10th Floor San Diego, CA 92101 San Diego, CA 92101

Dear Mayor Gloria and Council President Campbell:

San Diego’s hospitals are a core element of the city’s emergency response system. As foundational members of that system, we have a responsibility to share our concerns regarding the City of San Diego’s procurement process for Emergency Ambulance Service, 9‐1‐1‐ Response, Advanced Life Support Transport, and Standby Service.

Prior to the Public Safety and Livable Neighborhoods Committee meeting on February 9, we sent a letter expressing our disappointment in this procurement process, which included neither the expertise of base hospitals nor the diverse community representation that — especially during a pandemic — is essential to evaluating an emergency medical services (EMS) contract. Since then, we have learned about the AP Triton financial analysis and have been working with our members to understand the implications for health systems and the EMS patients they treat.

Our concerns fall into two major categories:

• Increased Costs & Administrative Burdens for Health Providers In its RFP response, Falck USA proposed that private providers (described by AP Triton as hospitals, care facilities, mental health providers, etc.) would not be offered “discounted” rates and would instead be billed out at the full rate. This approach is key to Falck USA achieving its revenue projections. Currently, providers are given discounted rates in recognition of the significant volume of both direct and transfer business. Doing away with these discounts would impose a costly new burden for health care providers — on top of the pandemic-induced financial challenges they are already navigating. The proposed policy could also lead to fewer contracts, thereby increasing costs and administrative burdens that would hinder timely patient transport.

• Increased Costs to Patients In its RFP response, Falck USA proposed that it would achieve 100% collection of Medicare copayments from patients who are transported by ambulance to obtain medical treatment at a hospital. Per the AP Triton analysis, a 100% collection seems unrealistic and raises some concern about how the collection process may increase costs for patients.

5575 Ruffin Road, Suite 225, San Diego, CA 92123

ADVOCATES FOR ACCESS TO HEALTHCARE FOR ALL CALIFORNIANS

As the largest employers in the region, San Diego’s hospitals understand the desire to keep health care costs low. In fact, health care is less expensive in San Diego due to the prevalence of managed care and risk-based arrangements. Shifting the cost of transport to hospitals by selecting a vendor that openly states they will not help keep providers’ rates low through volume discounts is not good for health care consumers. Furthermore, patients and health providers have endured over a year of health and financial uncertainties — we caution against any action that could exacerbate these challenges.

The City Council will have another opportunity to review the RFP on April 13, when the Independent Budget Analyst will provide its analysis of the AP Triton Consulting report. We ask that the council carefully consider all potential increased costs and administrative burdens before moving forward with the current proposal.

Please feel free to contact me with any questions. Thank you in advance for your time and consideration.

Sincerely,

Dimitrios Alexiou, FACHE President & CEO

CC: HASD&IC Board of Directors Councilmember Councilmember Joe LaCava Councilmember Raul Campillo Council President Pro Tem Stephen Whitburn Councilmember Councilmember Monica Montgomery Councilmember Sean Elo-Rivera Councilmember Marni von Wilpert

5575 Ruffin Road, Suite 225, San Diego, CA 92123

ADVOCATES FOR ACCESS TO HEALTHCARE FOR ALL CALIFORNIANS