STATE OF WASHINGTON DEPARTMENT OF HEALTH Olympia, Washington 98504 October 20, 2020 Theresa Boyle, Senior Vice President Strategy, Marketing, and Communication MultiCare Health System Sent by e-mail: [email protected] RE: Certificate of Need Application #20-48 MultiCare Health System Dear Ms. Boyle: We have completed review of the Certificate of Need application submitted by MultiCare Health System. The application proposes to establish an adult elective percutaneous coronary intervention (PCI) program at MultiCare Valley Hospital located in Spokane County. Enclosed is a written evaluation of the application. For the reasons stated in this evaluation, the department has concluded that the project is not consistent with the Certificate of Need review criteria identified below, and a Certificate of Need is denied. Washington Administrative Code 246-310-210 Need Washington Administrative Code 246-310-220 Financial Feasibility Washington Administrative Code 246-310-230 Structure and Process of Care Washington Administrative Code 246-310-240 Cost Containment This decision may be appealed. The two appeal options are listed below. Appeal Option 1: You or any person with standing may request a public hearing to reconsider this decision. The request must state the specific reasons for reconsideration in accordance with Washington Administrative Code 246-310-560. A reconsideration request must be received within 28 calendar days from the date of the decision at one of the following addresses: Mailing Address: Physical Address Department of Health Department of Health Certificate of Need Program Certificate of Need Program Mail Stop 47852 111 Israel Road SE Olympia, WA 98504-7852 Tumwater, WA 98501 Theresa Boyle, MultiCare Health System Certificate of Need Application #20-48 October 20, 2020 Page 2 of 2 Appeal Option 2: You or any person with standing may request an adjudicative proceeding to contest this decision within 28 calendar days from the date of this letter. The notice of appeal must be filed according to the provisions of Revised Code of Washington 34.05 and Washington Administrative Code 246-310- 610. A request for an adjudicative proceeding must be received within the 28 days at one of the following addresses: Mailing Address: Physical Address Department of Health Department of Health Adjudicative Service Unit Adjudicative Service Unit Mail Stop 47879 111 Israel Road SE Olympia, WA 98504-7879 Tumwater, WA 98501 If you have any questions, or would like to arrange for a meeting to discuss our decision, please contact the Certificate of Need Program at (360) 236-2955. Sincerely, Eric Hernandez, Program Manager Certificate of Need Enclosure EVALUATION DATED OCTOBER 20, 2020, FOR THE CERTIFICATE OF NEED APPLICATION SUBMITTED BY MULTICARE HEALTH SYSTEM PROPOSING TO ESTABLISH AN ADULT, ELECTIVE PERCUTANEOUS CORONARY INTERVENTION PROGRAM AT MULTICARE VALLEY HOSPITAL LOCATED WITHIN SPOKANE COUNTY APPLICANT DESCRIPTION MultiCare Health System (MHS), a Washington nonprofit corporation, is an integrated healthcare delivery system providing inpatient, outpatient, and other healthcare services primarily to the residents of Pierce, South King and Spokane Counties and, with respect to pediatric care, much of the southwest Washington area. MHS currently operates eight acute care hospitals and one behavioral health hospital. Below is a list of the licensed healthcare facilities solely owned and/or operated by MHS. [source: MultiCare Health System website and MHS 2018 Audited Financial Statements] Hospital Ambulatory Surgical Facility Tacoma General/Allenmore Hospital1 MultiCare Rockwood Eye Surgery Center Mary Bridge Children’s Hospital and Health Center MultiCare Good Samaritan Hospital MultiCare Auburn Medical Center In Home Services MultiCare Covington Medical Center Mary Bridge Infusion and Specialty Services MultiCare Deaconess Hospital MultiCare Home Health, Hospice, and MultiCare Valley Hospital Palliative Care NAVOS (psychiatric hospital In addition to the nine hospitals listed above, MHS has 50% ownership interest and CHI Franciscan Health has 50% ownership in an entity named ‘Alliance for South Sound Health’ that owns and operates a psychiatric hospital known as Wellfound Behavioral Health Hospital.2 The psychiatric hospital operates 120-beds in Tacoma within Pierce County. PROJECT DESCRIPTION This project focuses on MultiCare Valley Hospital located in Spokane County. The hospital, referenced in this evaluation as ‘Valley Hospital,’ is licensed for a total of 123 acute care beds and located at 12606 East Mission Avenue in Spokane Valley [99216]. The hospital provides a variety of healthcare services to the residents of Spokane County and surrounding communities. Table 1 below shows Valley Hospital’s 123 beds broken down by service. [source: DOH hospital licensing files] Department’s Table 1 MultiCare Valley Hospital Configuration of Licensed Acute Care Beds Services Provided Total Beds General Medical Surgical 123 Total 123 As of the writing of this evaluation, Valley Hospital provides a variety of general medical surgical services, including obstetric services, intensive care, and emergency services. The hospital is currently a Medicare and 1 While Tacoma General Hospital and Allenmore Hospital are located at two separate sites in Tacoma, they are operated under the same hospital license: HAC.FS.00000176. 2 Initial license issued on April 30, 2019—HPSY.FS.60919628. Medicaid provider and holds a three-year accreditation from the Joint Commission3. [source: DOH hospital licensing files] MHS submitted this application proposing to establish an adult, elective percutaneous coronary intervention (PCI) program at Valley Hospital. The project would increase the types of services provided at the facility, but does not propose to increase the total number of acute care beds. The applicant provided the following description of the new services. [source: Application, pdf 13] “The Valley Hospital catheterization laboratory ("cath lab") has been performing diagnostic cardiac cath services in one (1) mixed use cardiac cath/interventional radiology lab in December 2019 these facilities were expanded to include one (1) additional cardiac cath lab in order to expand cardiovascular services to include urgent and emergent cardiac catheterizations and PCI. With the Certificate of Need application, Valley Hospital seeks to include elective PCI within its services offered.” MHS states there is no capital expenditure associated with the addition of a PCI program and provided the following information to support this position. [source: Application, pdf 26 and May 12, 2020, screening response, pdf10] “MultiCare anticipates no start-up or initial operating expenses. The expansion of the emergent PCI program to include elective PCI services requires no construction, start-up costs, or capital expenditures. Thus, there are no financial impacts from capital expenditures of the project. Further, as stated above, Valley intends to provide emergent PCIs whether this CN application is approved or not.” When this application was submitted in February 2020, the hospital did not provide emergent PCI procedures. Within this application, MHS provided the following discussion about establishing an emergent PCI program at Valley Hospital. [source: Application, Project Introduction and Rational, pdf 5] “In July 2017, MultiCare Health System acquired Deaconess and Valley hospitals within Spokane County. In the process of evaluating and adjusting programs and services to best meet resident need, MultiCare determined that improved local access to Percutaneous Coronary Intervention (PCI) services was very important. MultiCare has observed a great number of Spokane Valley residents visit out-of-area providers to receive cardiology services. This indicates a deficiency of services within Spokane Valley, and with this in mind, Valley Hospital has expanded clinic services offerings, inpatient capabilities, and catheterization lab services to include additional diagnostics and lower acuity devices. Furthermore, MultiCare has resolved to begin offering emergent PCI services at Valley Hospital. In December 2019, an additional multi-use catheterization laboratory ("cath lab") room was completed to meet this need. MultiCare is thus in the process of fully implementing an emergent PCI capability at its Spokane Valley Hospital to improve local access in Eastern Spokane County, a process that is expected to be completed in early 2021. The development of emergent PCI services at Valley Hospital is occurring independently of any ability to provide elective PCI services. However, emergent and elective PCI services are highly complementary programs, in that addition of elective services to an existing emergent program requires little additional investment but significantly expands local access for non-urgent cardiac services to residents of East Spokane County. An elective PCI program, since it increases program utilization, also improves clinical expertise and operational efficiency.” If approved, MHS states that the adult, elective PCI program would be available in February 2021 and provided the following explanation and detail for its implementation timeline. [source: Application, pdf 16] 3 The Joint Commission is an independent, not-for-profit organization that accredits and certifies more than 22,000 health care organizations and programs in the United States. Joint Commission accreditation and certification is recognized nationwide as a symbol of quality that reflects an