CNN2302005 Service Area Residents Currently Have Ample Access to Hospice Care AHC Application Will Provide No Consumer Benefit AHC Hospice Application Meets None Of the CON Criteria AHCs Staffing Model Will Result In Poor Quality of Care ID: 1033783
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1. Opposition to AHC Hospice of Nashville CNN2302-005
2. Service Area Residents Currently Have Ample Access to Hospice CareAHC Application Will Provide No Consumer BenefitAHC Hospice Application Meets None Of the CON CriteriaAHC’s Staffing Model Will Result In Poor Quality of Care
3. Service Area Residents Currently Have Ample Access to Hospice CareAHC Application Will Provide No Consumer BenefitAHC Hospice Application Meets None Of the CON CriteriaAHC’s Staffing Model Will Result In Poor Quality of Care
4. Tennessee Hospice Provider for 20+ YearsProvides Hospice Services in Every County Proposed by ApplicantEarned “Superior Caregiver” Recognition from SHP Best Perfect CMS Hospice Care Index Score Caris Is A Nationally Recognized Hospice Provider
5. CheathamRobertsonMontgomerySumnerWilsonWilliamsonRutherfordDavidsonExisting Hospice ProvidersAbundant Existing Providers in Service Area
6. Source: Staff Summary pg. 5CheathamRobertsonMontgomerySumnerWilsonWilliamsonRutherfordDavidsonSurplus Existing Hospice Capacity in Service Area2,427 Patients of Surplus Capacity
7. Service Area Residents Currently Have Ample Access to Hospice CareAHC Application Will Provide No Consumer BenefitAHC Hospice Application Meets None Of the CON CriteriaAHC’s Staffing Model Will Result In Poor Quality of Care
8. Service Area Residents Currently Have Ample Access to Hospice CareAHC Application Will Provide No Consumer BenefitAHC Hospice Application Meets None Of the CON CriteriaAHC’s Staffing Model Will Result In Poor Quality of Care
9. AHC Nashville Website Advertises as a Provider of Hospice Care without CON Approval or a License
10. AHC Proposed StaffingRegistered Nurse1Certified Nursing Assistant1Masters Level Social Worker1Chaplain1Total Direct Patient Care Staff4Administrator0.5Patient Coordinator1Non-Patient Care Staff1.5Contractual Medical Director1Total Staff6.5AHC Not Committed to National Hospice and Palliative Care Organization (NHPCO) StandardsPer Agency staff report, AHC: “does not explicitly state a willingness to comply with the general staffing guidelines set forth by NHPCO”Admin Staff: NHPCO says it is “unlikely” a hospice “will be able to hire one individual who has the skill set to provide support for all these services” necessary for administering a hospice program. NHPCO categorizes administrative staff separately from leadership.Inadequate StaffingPer Staff Report and NHPCO Palliative Care Playbook for Hospices Staffing.
11. Hospice is a 24-Hour in-home serviceNursing services, physician services, drugs and biologicals must routinely be available on a 24-hour basis.1 RN is not sufficient to offer 24-hour nursing availabilityAll other services shall be available on a 24-hour basis, as necessary to meet the needs for management of patients’ terminal illness. AHC Staffing is Insufficient, Even if it is Day-1 StaffingInstead of providing staffing for the volume of patients it will serve in its first year, AHC has only provided Day-1 staffing. However, given the 24-hour nature of hospice care, the staffing is insufficient even for the first day of operations. Inadequate Staffing Under Tennessee RequirementsPer Rule 0720-28-.04 Standards for Home Care Organizations Providing Hospice Services
12. 7-County service area covers 3,643 square milesInadequate Staffing for Large Service Area
13. No Information Provided on Quality Control and MonitoringThe Regulations governing Certificate of Need Applications state that the Commission will consider the following general criteria in determining whether an application for a certificate of need should be granted: “For Hospice projects, whether the applicant has documented its existing or proposed plan for quality data reporting, quality improvement, and an outcome and process monitoring systems.” Tenn. Comp. R. & Regs. 0720-11-.01 (2)(l). The Applicant simply declined to respond to this standard in their Application simply stating “there should be no quality standards issues with our project.” Page 20. This is an insufficient response to evaluate a brand new provider of Hospice Services in Tennessee.
14. Service Area Residents Currently Have Ample Access to Hospice CareAHC Application Will Provide No Consumer BenefitAHC Hospice Application Meets None Of the CON CriteriaAHC’s Staffing Model Will Result In Poor Quality of Care
15. Service Area Residents Currently Have Ample Access to Hospice CareAHC Application Will Provide No Consumer BenefitAHC Hospice Application Meets None Of the CON CriteriaAHC’s Staffing Model Will Result In Poor Quality of Care
16. Tennessee Hospice provider for 47 yearsArea’s only Not-for-Profit Hospice provider Provides both Residential and In-Home Hospice servicesServes every county proposed by Applicant (and 5 others)Provided $1,131,603 in direct charity care in 2021 Alive Hospice
17. Enhanced Choice and Access?- NO Adequate choice of providers –16 agencies already serving the PSA Applicant has not identified any barriers to access No credible statements from providers or patients indicating services not readily accessible Proposed additional “choice” is clearly duplicative and unnecessaryNo Consumer Benefits
18. Enhanced Choice and Access?- NOAlive Hospice has never been unable or unwilling to provide services for any patient who seeks itLetter from AHC nursing home case manager says they have placed hospice patients with local agenciesProposed AHC Hospice would have access barriers -- not accessible to commercial plan enrollees or TennCare enrolleesNo Consumer Benefits
19. “Continuity of Care”?- NOCommon ownership ≠ continuity of careHospice & nursing home are different licensed agenciesHospice & nursing home have different nurses and caregiversHospice services provided in different settingNo Consumer Benefits
20. Lower Charges?- NOApplicant’s claim of lower average charges is illusory and unrealisticApplicant plans to serve 100% Medicare populationMedicare charges are determined by CMS – not the provider“Average” charges fluctuate among providers due to differing levels of care providedNo Consumer Benefits
21. Criteria call for a Community Linkage Plan Applicant cites letters of support for its community linkage plan Letters originally submitted: mostly from affiliated nursing home staff Late-filed letters: not relevant to hospice, and/or lack credibilityNo Community Linkage Plan
22. Applicant intends to generate more patients by “educating” the public and providers about hospice Alive Hospice and other existing providers commit substantial resources to community education and outreachExpecting immediate results in increasing hospice penetration rate is unrealisticNo Community Linkage Plan
23. Service Area Residents Currently Have Ample Access to Hospice CareAHC Application Will Provide No Consumer BenefitAHC Hospice Application Meets None Of the CON CriteriaAHC’s Staffing Model Will Result In Poor Quality of Care
24. This application does NOT meet the applicable criteria, and the CON should be DENIED Conclusion
25. Numerous existing providers serving the PSA No letters from community providers or patients indicating lack of access to services Need formula in Criteria & Standards: PSA is vastly overserved Target patient base of discharges from small nursing home is insufficient for feasible level of utilization Summation: Need Not Demonstrated
26. Proposed staffing is inadequate4.0 FTE patient care staff to provide 24 hour per day care throughout 7 county PSA HFC Staff: Applicant does not explicitly confirm compliance with NHPCO staffing guidelines No info provided on quality control and monitoring Summation: Quality Standards Not Met
27. Proposed new hospice agency is duplicative and harmful to existing providers “Continuity of care” for discharged nursing home patients is negligible and illusory Will not result in lower patient charges No realistic community linkage planSummation: No Consumer Benefits