July 3, 2017

Erik O. Bodin, III

Director

Office of Licensure and Certification

Virginia Department of Health

9960 Mayland Drive, Suite 401

Henrico, Virginia, 23233

Re:      12 VAC 5-230 State Medical Facilities Plan Periodic Review

Dear Mr. Bodin:

            I am writing on behalf of HCA Virginia to comment on the State Medical Facilities Plan (“SMFP”), which is currently subject to periodic review.

            As an initial matter, HCA Virginia believes that the SMFP is valuable and should be retained.  The SMFP, however, should be designed to ensure consistency, should be updated regularly to reflect current standards of healthcare delivery, and should be applied consistently.

            The SMFP Task Force, set forth in Virginia Code § 32.1-102.2:1, should be reconvened to discuss the SMFP, consider the various public comments, and make recommendations on potential revisions.

            HCA Virginia believes that several provisions of the SMFP should be subject to focused review and should be revised.  These include, but are not limited to:

• Definitions.

• Radiation Therapy and Stereotactic Radiosurgery (“SRS”) standards.For example, new standards should be developed to measure utilization of linear accelerators capable of both performing both SRS and traditional radiation therapy.

• Open Heart Surgery standards.

• Psychiatric and Substance Abuse Beds standards.For example, 12 VAC 5-230-860 should be reworded to make clear that approved-but-not-yet-operational beds are included in the inventory.

• Neonatal Special Care Services standards.For example, 12 VAC 5-230-970.D should be reworded so that it cannot interpreted to mean that diminution of utilization at existing specialty-level NICU services can disqualify an otherwise meritorious new program in a planning district with only a single NICU provider. In those cases where there is only one NICU provider in the planning district, the requirement that the applicant demonstrate that the introduction of the new NICU service will not significantly reduce the service volumes of the sole existing NICU provider potentially can be interpreted to create a disqualifying barrier to any new service being introduced. The SMFP should be amended to reflect unique circumstances in situations where there is only one existing provider of the service.

  HCA Virginia looks forward to the opportunity to provide specific comments on the SMFP in response to other public comments, to having a representative member included in the SMFP Task Force, and to the swift conclusion of this SMFP review and revision process so that the standards are current and relevant to today’s healthcare environment.  Thank you for considering these comments. 

  Sincerely,

   

           Daniel L. Thurman

           Director of Certificate of Need

           HCA Virginia