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STATE AGENCY ACTION REPORT
ON APPLICATION FOR CERTIFICATE OF NEED
A. PROJECT IDENTIFICATION
1. Applicant/CON Action Number
Catholic Hospice of Central Florida, Inc./CON #10069
14875 N. W. 77 Avenue, Suite 100 Miami Lakes, Florida 33014
Authorized Representative: Ms. Julie E. Smith (850) 425-2444
Memorial Hospital-Flagler, Inc. d/b/a Florida Hospital
HospiceCare/CON #10070
770 West Grenada Boulevard, Suite 304 Ormond Beach, Florida
32147
Authorized Representatives Mr. David Ottati Ms. Diane
Godfrey
(386) 671-2138 (407) 303-9659
Odyssey HealthCare of Collier County, Inc. d/b/a Odyssey
HealthCare of Central Florida/CON #10071 717 North Harwood, Suite
1500
Dallas, Texas 75201
Authorized Representative Mr. Jason S. Howard (214) 922-9711
United Hospice of Florida, Inc./CON #10072 1626 Jeurgens
Court
Norcross, Georgia 30093 Authorized Representative Mr. Neil L.
Pruitt, Jr.
(770) 925-4788
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CON Action Numbers: 10069, 10070, 10071, & 10072
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2. Service Area/Subdistrict
Hospice Service Area 7B, Orange and Osceola Counties
B. PUBLIC HEARING
A public hearing was not held or requested regarding the
proposals to establish a hospice program in Hospice Service Area
(SA) 7B. However, letters of support were submitted, as discussed
below.
Catholic Hospice of Central Florida, Inc. (CON #10069)
submitted
approximately 248 letters of support with its application. The
letters of support were from physicians, businesses, commissioners,
educators, faith-based organizations, government leaders, community
organizations
and other members of the community at large. One hundred and
forty seven letters had Orange or Osceola County (SA 7B) addresses.
These
include letters from 70 residents, 33 churches and faith based
organizations, 27 community organizations and businesses, 10
physicians, five local government officers, and five local health
care
facilities. The applicant‟s support letters generally indicate
that: Catholic Hospice has excellent educational and outreach
services; project approval would increase access to faith-based
services, the community
would benefit from a faith based approach to hospice care,
Catholic Hospice will have bilingual staff ideally suited to meet
the needs of the
diverse community, and that Catholic Hospice provides quality
compassionate care to its patients.
Mildred Fernandez, Orange County Commissioner, John “Q”
Quinones, Osceola County Commissioner, Orlando City Commissioner
Tony Ortiz, Osceola County Sheriff Robert E. “Bob” Hansell, and
Captain Miguel A.
Pagan of the Orange County Sheriff‟s Department provided letters
which contained one or more of the above statements. The
applicant‟s letters
from local health care facilities include Shannon Elswick,
President, Orlando Regional Medical Center, Orlando Health;
Clarence H. Brown III, M.D., President and CEO of MD Anderson
Cancer Center – Orlando,
John S. Lord, Chairman, Nemours Board of Directors (Nemours has
an Orlando outpatient clinic and CON approval to construct a
children‟s
hospital in Orange County), Diane Boodram, NHA, Executive
Director of Rio Pinar Health Care (a 180-bed nursing home in
Orlando), and Kevin Johnson, Executive Director of Bishop Grady
Villas (an ALF in St. Cloud
- Osceola County). The applicant‟s support letters from local
physicians, churches and faith-based organizations, and community
organizations and businesses all essentially contain one of more of
the above
statements.
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CON Action Numbers: 10069, 10070, 10071, & 10072
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The remaining 101 letters of support were from physicians,
businesses, organizations and residents of Seminole, Miami-Dade and
Monroe
Counties.
Memorial Hospital Flagler, Inc. d/b/a Florida Hospital
HospiceCare (CON #10070) submitted 53 letters of support with its
application. The letters of support were from clergy, community
leaders and
organizations, assisted living facilities, volunteers, skilled
nursing facilities, and Seventh Day Adventist Church/Sunbelt, Inc.
Florida Hospital affiliates. Twenty-two of the letters of support
were from Florida
Hospital or one of its affiliates such as Florida Hospital
Orlando Palliative Care Program, Florida Hospital Cancer Institute,
or Florida Hospital
Memorial Home Health. These letters emphasized that the addition
of a hospice program would be a complimentary extension of the
continuum of care that already exists as a part of the Florida
Hospital network.
Thirteen letters of support were submitted by community leaders
and organizations. The applicant‟s letters generally indicated
that: Florida
Hospital is a multi-faceted health care system that has the
infrastructure to support a hospice organization; Florida Hospital
provides quality care and has “a deep understanding of the medical,
social and end of life
needs of the residents in our service area”, and various
training and educational opportunities would be available should
the applicant be awarded the CON.
John “Q” Quinones, Osceola County Commissioner and Rick
Daigneault,
LMHC, Health Services Administrator for Orange County Government
Health Services Division, provide letters which contained one or
more of the above statements. The letters from representatives of
local
organizations also cite several of the above statements. The
Rev. Lizette M. Acosta, Director of the Latino/Latina Studies
Program (LLSP) at Asbury Theological Seminary indicates that LLSP
students are provided
supervised ministry experience at Florida Hospital East Orlando
and that the addition of hospice would be of great service to the
(Latino)
community. Marinella Castroman RN, CEO and Marketing Director of
Select Specialty
Hospital – Orlando and Rose O‟Neil CEO of Select Specialty
Hospital – Orlando North provided general letters of support. Ms.
Castroman stated
that she sees the need based on their (Select‟s) patient
population and fully supports Florida Hospital‟s application. Ms.
O‟Neil cites her facility‟s partnership with Florida Hospital and
the need for hospice care
for patients discharged from Select. Representatives of nursing
homes providing general letters of support include: Diane Boodram,
NHA, Executive Director of Rio Pinar Health Care (a 180 bed nursing
home in
Orlando), Abigail Ashe, NHA Rosewood Health & Rehabilitation
Center (120 beds - Orlando), Tristan S. Mohadeo, Executive Director
of Colonial
Lakes Health Care (180 beds -Winter Garden) and Mindy Wright,
MHSA,
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CON Action Numbers: 10069, 10070, 10071, & 10072
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Regional Sales Consultant for Sea Crest Healthcare Management,
which manages several Orange and Osceola County facilities. Texus
Wallace,
representing Almark Health Services, Inc. indicates his
company‟s three small ALFs have worked with Florida Hospital for
over 16 years and that
the addition of hospice care for Florida Hospital would
effectively improve continuity of care for the ALF population.
The majority of the applicant‟s letters are from representatives
of facilities that are part of the Seventh Day Adventist
Church/Sunbelt, Inc. health care chain. Some of these are
summarized below.
Joseph D. Portoghese, MD, Chief Academic Officer and General
Surgery
Residency Program Director at Florida Hospital, indicates that
the hospice program will open the possibility of establishing an
accredited training program in Palliative Care Medicine. Dr.
Portoghese concludes
that the project has the potential for multiplying the positive
effect for the community by alignment with a hospital big enough to
support medical
education. Gregory K. Ellis, M. Div., B.C.C., Administrative
Director for Pastoral
Care at Florida Hospital indicates that through the hospice
program, Florida Hospital would be able to serve the community in
terms of training opportunities for pastors in its Clinical
Pastoral Education (CPE)
program. CPE provides training for pastors in the specialized
ministry of spiritual care within the clinical context and Mr.
Ellis indicates that the
hospice environment is a “very fertile ground for such learning
and training to take place”. He indicates that his CPE training
included both traditional hospital and hospice and that the hospice
portion “was
transformational and life changing”. Kenneth Zill, Executive
Director of Volunteer Services at Florida Hospital
states his program presently has over 3,000 volunteers who
provide nearly 300,000 hours annually. They serve in all Florida
Hospitals,
urgent care centers, community clinics and numerous
administrative roles across the system. Mr. Zill indicates that
this network will yield a much faster ramp-up of dedicated hospice
volunteers than would
otherwise be possible.
Cary Smith, NHA, Vice President of Regional Operations of
Adventist Care Centers which operates four nursing homes in the
Orlando area indicates that his “facilities would greatly welcome
an opportunity to
effectively collaborate with a Florida Hospital HospiceCare
program by providing support for their long-term care patients (and
that) having this type of program with Florida Hospital would
improve the continuity of
care for these residents of our community”. The applicant states
it
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CON Action Numbers: 10069, 10070, 10071, & 10072
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intends to enter into contracts with one or more Florida
Hospital facilities, Adventist Care Center skilled nursing
facilities and other
providers in the service area.
Eight of the letters were from either volunteers of Florida
Hospital HospiceCare or families that were served by the hospice in
Ormond Beach and Palm Coast, Florida.
Odyssey HealthCare of Collier County, Inc. d/b/a Odyssey
HealthCare of Central Florida (CON #10071) submitted 50 letters
of
support with its application. These were from assisted living
facilities, nursing homes, retirement communities, and families
that received
services through Odyssey‟s other hospice programs. The 15
letters provided by nursing homes, assisted living facilities and
retirement communities stated that having an additional hospice
provider in the
area could only cause all other area hospices to provide better
care and services to its patients. The letters also expressed a
need for better
hospice education and a belief that the applicant can adequately
provide such education. The remaining 35 letters of support were
from families that received services from Odyssey-Daytona and
Odyssey-Miami. These
letters expressed gratitude to Odyssey for its caring and
compassionate attitude when providing comfort and a sense of
dignity for its patients and their families. Although the applicant
provided letters of support
from area ALFs and nursing homes, none provided agreements to
contract for inpatient services.
United Hospice of Florida, Inc. (CON #10072) provided 58 letters
of support with its application. These were from hospitals, nursing
homes,
assisted living communities, local businesses and physicians.
The applicant also provided letters of support from UHS-Pruitt
Subsidiaries and patients and families who have received services
from United Health
Services in the past. Thirteen letters were from the local
service area. A social worker from Florida Hospital Cancer
Institute offers her support of
United Hospice to provide additional hospice services. A letter
from the CEO, Rebecca Brewer, of St. Cloud Regional Medical Center
states they are willing to work cooperatively with this hospice
provider, and will
enter into appropriate contractual relationships to ensure that
hospice patients in need of inpatient care receive it at their
hospital. The other
letters of support emphasized the importance of allowing
families to choose the provider that best fits their needs and that
adding a new hospice program to the local service area will raise
the standard through
competition with existing hospice providers. United Hospice‟s
subsidiaries provided five letters of support. United Medical
stated its interest in coordinating to provide medical equipment
services for
patients in the service area. United Pharmacy Services stated
its willingness to supply pharmaceuticals and medical supplies to
United
Hospice. UHS Pruitt-Corporations states its interest in working
with
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CON Action Numbers: 10069, 10070, 10071, & 10072
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United Hospice in coordinating and providing assessment and
dietary counseling to the residents of Orange and Osceola Counties.
United
Rehab stated it is prepared to provide physical, occupational,
speech and respiratory therapy services under a contracted
agreement with United
Hospice. The remaining 40 letters of support were from families
previously served by UHS. The letters expressed thanks and
gratitude for superior hospice services.
C. PROJECT SUMMARY
Catholic Hospice of Central Florida, Inc. (CON #10069) proposes
to
establish a new hospice program in Hospice Service Area 7B,
Orange and Osceola counties. Catholic Hospice of Central Florida,
Inc. is a newly formed entity whose sole member is Catholic
Hospice, Inc. and as such
has no operational history. Catholic Hospice, Inc., a
faith-based organization, has a history of providing hospice
services in Miami-Dade,
Monroe and Broward Counties. The proposed total project cost is
$334,800 with year one total operating
costs of $2,207,564 and year two costs of $5,065,314. The
applicant agrees to condition award of the CON as follows:
1. Catholic Hospice will respond to patient referrals within two
hours of receipt of the referral.
2. Catholic Hospice staff will contact all patients admitted
within 48
hours after admission and then again after seven days to
ensure
patient/family needs are being met. 3. After hours phone calls
to Catholic Hospice by patients and
families will be answered by hospice staff
4. Catholic Hospice RN case managers, social workers and
chaplains will use laptop computers in the field to collect and
input clinical information into the patient database system in
order to maximize
available clinical information and responses to patient and
family needs.
5. Catholic Hospice will assess the quality of care via meetings
with
all contracted hospitals and long term facilities to review
services
provided to patient and families as well as service and
responsiveness to the needs of these providers.
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CON Action Numbers: 10069, 10070, 10071, & 10072
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6. Catholic Hospice will provide an emergency pharmaceutical kit
(E-Kit) to all hospice patients admitted in their home, as
appropriate
and ordered by a hospice physician, in order to provide emergent
access to palliative medications in the event of a medical crisis
by
the patient at night or on weekends, when the patient‟s access
to palliative medications may be limited or not timely. The E-Kit
will be provided in accordance with all applicable state and
federal
dispensing laws and is intended to be responsive to patient and
family needs as well as enhanced patient care after regular
business hours at night and on weekends.
7. Catholic Hospice will contract with OnePoint Patient Care
Pharmacy, a hospice pharmacy, for hospice related drugs,
pharmaceuticals and biologicals in accordance with state and
federal dispensing requirements and statutes. OnePoint Patient
Care Pharmacy will dispense the hospice related drugs,
pharmaceuticals and biological for Catholic Hospice patients.
The
dispensing will include home delivery of medications at no cost
to Catholic Hospice patients and families in order to improve
hospice services and reduce the caregiver burden of the family
caregivers
while promoting patient satisfaction. 8. Catholic Hospice will
contract for durable medical equipment
(DME)/home medical equipment (HME) from a specialty hospice
medical equipment provider who understands and is responsive to
the unique needs of hospice patients and families. 9. Catholic
Hospice will offer individual and group grief counseling
services to any resident of the service area in need of such
services regardless of any prior relationships with Catholic
Hospice.
10. Catholic Hospice will conduct annual memorial services for
those primary caregivers and families served Catholic Hospice as
well as
any other resident of the service area. 11. At initiation of
service, Catholic Hospice will become an
organizational member of Florida Hospice and Palliative Care
(FHPC) as well as the National Hospice and Palliative Care
Organization (NHPCO). 12. At initiation of service, Catholic
Hospice will become a member of
the Tri-County Volunteer Organizations Active in Disasters
(Tri-VOAD) in order to collaborate with the Community Emergency
Response team (CERT) on disaster preparedness.
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CON Action Numbers: 10069, 10070, 10071, & 10072
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13. Catholic Hospice will provide community support groups for
those primary caregivers and families served by Catholic Hospice as
well
as any other resident of the service area.
14. Catholic Hospice will provide a children‟s annual grief
camp, Camp Hope, for those families and caregivers who have
children served by Catholic Hospice as well and any other resident
of the service
area. 15. Catholic Hospice will target diversity and cultural
outreach
activities to Hispanics. Catholic Hospice will advertise in
Hispanic language papers, and provide culturally relevant material
in
Spanish. 16. Catholic Hospice will provide cultural diversity
and sensitivity
training to all staff members, including but not limited to
Hispanic culture.
17. Bereavement services will include special outreach to
Hispanic
children, including introduction to hospice at school
counselor
level, offering grief counseling through school administration
to grief-stricken children throughout the school year, and
identifying children who would benefit from Camp Hope.
18. Catholic Hospice will target the recruitment and retention
of
bilingual (English/Spanish) staff. Catholic Hospice will commit
that at least 20 percent of its staff in Orange and Osceola
Counties will be bilingual.
19. Catholic Hospice will provide community education seminars
on
the following topics: Bridging the Gap at End of Life, Care at
the
Time of Dying, Care of the Actively Dying, Advanced Directives,
Alzheimer‟s and Related Disorders, Domestic Violence, End of
Life
Communication, Fall Prevention, Florida Assisted Living, and
Hospice 101.
20. Catholic Hospice will initiate the “Wishes Granted” program
in Service Area 7B.
21. Catholic Hospice commits to opening its main office in
the
Kissimmee area to best serve all the people of Service Area
7B.
Memorial Hospital-Flagler, Inc. d/b/a Florida Hospital
HospiceCare (CON #10070) proposes to establish a new hospice
program in Hospice
Service Area 7B, Orange and Osceola Counties. Memorial
Hospital-Flagler, Inc. is one of the 17 acute care facilities in
Florida owned by
Adventist Health System. Florida Hospital and Florida
Hospital
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CON Action Numbers: 10069, 10070, 10071, & 10072
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HospiceCare are a part of the Adventist Health System. Six
Florida Hospital facilities are located in Service Area 7B: Florida
Hospital
Apopka, Florida Hospital Celebration, Florida Hospital East
Orlando, Florida Hospital Kissimmee, Florida Hospital Orlando and
Winter Park
Memorial Hospital. The proposed total project cost is $306,380
with year one operating costs
of $2,323,888 and year two costs of $3,261,895. The applicant
agrees to condition award of the CON as follows:
1. Florida Hospital HospiceCare will provide programs and
services for residents of Service Area 7B that are outside the
Medicare
hospice benefit which will include community hospice education
and community bereavement. This would also include the development
of Project StoryKeeper as a means of providing
training for hospice staff and volunteers that can be put to use
in establishing a patient's family history/legacy. Project
StoryKeeper
allows patients to record their life stories as part of their
legacy to their loved ones, so that their stories can be told and
shared long after they have passed away. Also included is the
development of a
pet therapy program for hospice patients. Pet therapy offers
psychological benefits in terms of emotional connection, stress
reduction, and reduced feelings of loneliness or isolation.
2. Florida Hospital HospiceCare will provide an ongoing
education
program on hospice care to provide easily accessible information
for medical staff members of the Florida Hospitals in Orange and
Osceola Counties and resident physicians and fellows in Florida
Hospital's teaching program.
3. Florida Hospital HospiceCare commits to develop and offer
a
structured curriculum for Florida Hospital's Chaplaincy
Residents. At a minimum the program will include hospice
overview,
admission requirements, patient and family satisfaction results,
and spiritual considerations in end-of-life care.
4. Florida Hospital HospiceCare commits to the following
initiatives to improve the quality of hospice care offered:
Pain assessment on admission and by the second day of
admission (within 48 hours);
Provide palliative care modalities including radiation
therapy;
Encourage additional staff credentialing for physicians, nurses,
chaplains, and social workers through a certification
reimbursement program;
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CON Action Numbers: 10069, 10070, 10071, & 10072
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Maintain accreditation by The Joint Commission (formerly
known as the Joint Commission on Accreditation of Health Care
Organizations)
5. Florida Hospital HospiceCare commits to enter into agreements
with one or more of the six Florida Hospital hospitals (Apopka,
Celebration Health, East Orlando, Kissimmee, Orlando and Winter
Park Memorial) and one or more Adventist Care Centers (skilled
nursing facilities) in Service Area 7B to provide inpatient
hospice
services to residents of Orange and Osceola Counties. 6. Florida
Hospital HospiceCare commits to provide volunteer services
to hospice patients that substantially exceeds the five percent
requirement mandated under the Medicare Conditions of
Participation. Based on the success of its Flagler and Volusia
program, Florida Hospital HospiceCare commits to a minimum of 10
percent of its hours of care being provided by hospice
volunteers. The additional commitment of volunteer hours will
begin with the second year of operation.
7. Florida Hospital HospiceCare commits to provide programs for
the
Hispanic population which will include support from or
involvement of bilingual staff and volunteers, translated
literature, training on cultural differences and competencies, and
flexible programming to meet identified needs. Bereavement services
will
include outreach to the Hispanic population of Service Area
7B.
8. Florida Hospital HospiceCare commits to develop a community
resource information website in the first year of operation. This
educational site will include various lay and professional
education
pieces related to chronic illness, death, dying, and
bereavement.
9. Florida Hospital HospiceCare commits to develop a community
advisory board composed of residents inclusive of both the Orange
and Osceola communities. The purpose of the community advisory
board is to provide input and feedback about service area needs
and recommendations for consideration in future program
development.
10. Florida Hospital HospiceCare commits to minimum annual
funding
of $10,000 towards a "Special Wish Fund" designated for the
end-of-life wishes for Florida Hospital HospiceCare patients and
their families. This commitment would begin in the second year
of
operations.
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11. Florida Hospital HospiceCare commits to open two offices in
the
first year of operation. One office will be opened in Osceola
County on the campus or in proximity to Florida Hospital Kissimmee.
The
Orange County office will be located on the campus or in close
proximity of an Orange County facility to best suit the needs of
the Clinical Pastoral Education, Medical Education, and Palliative
Care
programs. Odyssey HealthCare of Collier County, Inc. d/b/a
Odyssey
HealthCare of Central Florida (CON #10071) proposes to establish
a new hospice program in Hospice Service Area 7B, Orange and
Osceola
Counties. The applicant states that its sole shareholder and
parent is Odyssey HealthCare Operating B, LP. The parent is stated
to have 92 Medicare-certified hospice programs in 29 states.
Odyssey is licensed in
Florida as Odyssey HealthCare of Marion County, Inc. and serves
three hospice service areas (SA): SA 11 (Miami-Dade and Monroe
Counties),
SA 4B (Volusia and Flagler Counties) and as of January 1, 2010
SA 3B (Marion County).1
The proposed total project cost is $635,608 with year one
operating costs of $1,945,888 and year two costs of $3,490,434. The
applicant agrees to condition award of the CON as follows:
1. The applicant will provide supportive hospice services, such
as but
not limited to: palliative radiation therapy and palliative
chemotherapy related to the patient's terminal diagnosis. This will
be measured via a signed declaratory statement by applicant
which
may be supported via a review of patient medical records.
2. The applicant will provide continuous care. This will be
measured
via a signed declaratory statement by applicant, which may be
supported via a review of patient medical records.
3. The applicant will implement the "Care Beyond' Program. This
will
be measured via a signed declaratory statement by applicant.
4. The applicant will provide hospice services 24 hours a day,
seven
days a week including weekend care as indicated by the patient's
medical condition. This will be measured via a signed declaratory
statement by applicant, which may be supported via a review of
patient medical records.
1 Odyssey HealthCare of Marion County, Inc. became licensee for
hospice Service Areas 4B & 11
effective November 1, 2009 and added Marion County to its
license effective January 1, 2010. Odyssey had previously operated
as Odyssey HealthCare.
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CON Action Numbers: 10069, 10070, 10071, & 10072
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5. The applicant will admit all eligible patients without regard
to their
ability to pay. This will be measured by the applicant's
Medicare certification which requires this standard.
6. The applicant commits to having every patient being assessed
by a
physician upon admission to the hospice. This will be
measured
via a signed declaratory statement by the applicant, which may
be supported via a review of patient medical records.
7. The applicant will immediately implement its performance
improvement (PI) plan including the following assessments: pain
management, family satisfaction, employee satisfaction, and
referral source satisfaction. This will be measured via a signed
declaratory statement by the applicant, which may be supported
via a review of patient medical records.
8. The applicant will make available a range of non-covered
supplementary therapies such as but not limited to: pet, music,
massage, aroma and other holistic treatments. This will be
measured via a signed declaratory statement by the applicant,
which may be supported via a review of patient medical records.
9. The applicant will implement Odyssey's triage and on-call
programs upon licensure. These programs provide for
uninterrupted 24-hour care seven days a week. Further
explanation of the program is offered in the application narrative.
This will be measured via a signed declaratory statement by the
applicant.
10. The applicant will establish a local ethics committee within
the
first year of operation. This will be measured via submissions
of the names and other relevant information of the ethics
committee
members and the related schedule of meetings to the Agency. 11.
The applicant will establish a local medical advisory committee
within the first year of operation. This will be measured via
submissions of the names and other relevant information of the
Medical Advisory Committee members and the related schedule of
meetings to the Agency.
12. The applicant will provide educational programs, including
but not limited to, in-service training (components of Odyssey
University) resources to the community, including nursing homes,
assisted
living facilities, and the Council on Aging. In-service training
would be offered to registered nurses, social workers,
administrators and other staff that would benefit from an
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CON Action Numbers: 10069, 10070, 10071, & 10072
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increased knowledge of hospice care and services. The applicant
will host at least one seminar annually during the first two years
of
operation for clergy and community faith leaders (The Clergy End
of Life Education Program), to enhance spiritual support for
hospice patients in the district. This will be measured via a
signed declaratory statement by the applicant.
13. The applicant will provide patients, family members and
referral sources with information of services provided by the Dream
Foundation. The Dream Foundation is the first national group of
its kind that exists for terminally ill applicants over the age
of 18. Through its Day Dreams (a program for terminally ill adults
over
the age of 65), Emergency Dreams and Quality of life Dreams, the
Dream Foundation provides patients and families with a sense of
completion and fulfillment. Odyssey has partnered with the
Dream
Foundation to improve care for our patients and to advance our
mutual interests in the field of hospice. This will be measured
via
a signed declaratory statement by the applicant.
14. The applicant, through Odyssey HealthCare, Inc. or the
Odyssey
VistaCare Hospice Foundation, will make a $25,000 contribution
to an appropriate not-for-profit entity in the community to fund
education for end-of-life issues. Upon approval, Odyssey will
meet
with the Area Council on Aging or similar organizations to
identify and determine the most appropriate entity within the
community
related to education for end-of-life issues. This will be
measured via a signed declaratory statement by the applicant and
evidence of funds provided to the not-for-profit entity.
15. The applicant will commit to 0.5 FTE the first year of
operation to
evaluate the need, if any, for an expanded children's
hospice
program in the community including, but not limited to, the need
for a children's program that offers an expanded hospice benefit
for
patients up to age 21. The program would focus on longer term
services for patients who may not otherwise qualify for hospice
such as those with developmental conditions, cancers, chronic
illnesses or brain injury that shorten lives and place special
demands on families. If during the first year of operation it
is
determined that existing children's hospice services in the
community are available to meet local needs, the applicant will
donate $25,000 to support existing local children's hospice
programs. If after this first year there is found to be a need
for additional children's hospice services, a child and family
support program interdisciplinary team will be established to
support the
needs of this target population. This will be measured via a
signed declaratory statement by the applicant.
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16. The applicant will commit to 0.5 FTE the first year of
operation for development efforts regarding community bereavement
programs
in the community. The bereavement programs will be broadly based
to extend beyond the families of patients admitted to
Odyssey HealthCare. These programs will be an extension of the
programs currently offered in the hospice service area. The
applicant will provide bilingual staff to provide bereavement
services to the Hispanic population, including Hispanic
children. At a minimum, one bereavement group consisting of
approximately eight sessions will be offered by the end of the
first year of
operation. As the bereavement client census increases after one
year, full-time staff will be employed. This will be measured via
a
signed declaratory statement by the applicant. 17. The applicant
will commit to the provision of programs for the
Hispanic and other minority populations which will include
support from or involvement of bilingual staff, translated
literature,
training on cultural differences and competencies and flexible
programming to meet their unique needs. Hospice staffing will
reflect the racial and ethnic mix of the local community
served.
This will be measured via a signed declaratory statement by the
applicant.
18. The applicant will develop a community resource library
during the first year of the proposed hospice's operation. The
library will
include various lay and professional education pieces related to
chronic illness, death, dying and bereavement. This will be
measured via a signed declaratory statement by the applicant.
19. The applicant commits that the Odyssey VistaCare Hospice
Foundation will facilitate the provision of a children's
bereavement
camp in Florida by the end of the first year of operation,
similar to what Odyssey currently provides via Odyssey's SkyCamp,
Camp
Healing Tree and Camp Odyssey. This will be measured via a
signed declaratory statement by the applicant.
20. The applicant will have a minimum staff of at least three
community education representatives, expanding community
awareness of hospice services and educating local medical staff,
community leaders and potential hospice patients as to the benefits
of and availability of hospice care. Compliance with this
condition will be measured via submission of an annual report
confirming that at least three community education representative
staff members are employed at the proposed new service and
active
in the local community. Additionally, if approved, Odyssey will
provide education, training and assistance in development of
respite care policies, procedures and protocols to nursing
homes.
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CON Action Numbers: 10069, 10070, 10071, & 10072
15
21. Hospice Service Area 7B includes two counties: Orange
and
Osceola. Odyssey commits to the immediate development of its
main office in Orange County and a satellite office in Osceola
County by the end of year one of operation. The applicant
commits to become accredited by the Joint Commission and the
National Institute for Jewish Hospice by the end of its second year
of
operation.
22. The applicant commits to medical directors assessing every
patient
on admission and providing visits in home or place of residence.
The medical director is to be board-certified in hospice and
palliative care medicine or will apply for board-certification
within five years of employment.
23. The applicant commits that every patient will be contacted
on a daily basis. The applicant commits to sponsoring two to
four
education seminars per year for physicians, long-term care
facilities and assisted living facilities (ALFs). The focus of
these seminars is to educate the local health care community on
the
provision of hospice services within ALFs and other long-term
care facilities: a coordinated plan of care for the patient,
increased support for patient, family and facility staff, and the
provision of
equipment, medication and supplies.
United Hospice of Florida, Inc. (CON #10072) proposes to
establish a new hospice program in Hospice Service Area 7B, Orange
and Osceola Counties. United Hospice is a wholly owned subsidiary
of United Health
Services of Florida, Inc. The parent company, United Health
Services, Inc., is a part of the United Health Services-Pruitt
family of companies. United Health Services, Inc. is a holding
company which owns and/or
operates, through its subsidiaries, 71 long-term care
facilities, 25 hospice programs, 13 home health care agencies, five
pharmacies, a
health care management company, a nutritional services company,
a clinical services company, and medical supply company and 14
SOURCE offices.2 United Health Services, Inc. (UHS), manages its
many
subsidiaries through its corporate office located in Norcross,
Georgia.
The proposed total project cost is $247,009 with year one
operating costs of $1,841,126 and year two costs of $4,775,746. The
applicant agrees to condition award of the CON as follows:
2 The State of Georgia & UHS-Pruitt websites indicate
UHS-Pruitt subsidiary UniHealth Solutions oversees UHS
participation in SOURCE. SOURCE is an acronym for Service Options
Using Resources
in Community Environments and is the State of Georgia‟s Medicaid
long-term care diversion program.
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CON Action Numbers: 10069, 10070, 10071, & 10072
16
1. UHS Home and Community Based Services Provider: Upon CON
approval, United Hospice's ultimate parent, UHS, will develop,
in
conjunction with United Hospice, UHS' family of services and
companies in Subdistrict 7B and will enhance the hospice
services
available to area residents by making such a service available
not only to United's hospice patients, but also to any other
existing hospice provider who wishes to contract for such services.
These
services and companies include United Home Care, United Rehab,
United Medical, United Pharmacy Services and United Clinical
Services. This will be measured by a signed declaratory
statement
submitted by United Hospice to the Agency.
2. Hispanic Outreach: Reflective of its commitment to enhancing
access to end-of-life care of Hispanic residents in Subdistrict 7B,
the applicant has conditioned approval of its application on
the
provision it will implement and maintain an African American
outreach program.
• A bilingual (Spanish speaking) staff member will be
responsible
for the outreach initiatives. This individual's objective will
be to
coordinate staff activities, plan events and serve as a key
contact within community leaders.
• By the end of the second full year of operation, 40 percent of
the staff serving Osceola County will be bilingual to reflect
the
demographic make-up of the community, including Spanish speaking
physicians, nurses, home health aides, chaplains and social
workers.
• Marketing and family educational materials, as well as all
hospice admissions forms, advance directives, bereavement
materials and any other written materials used in the provision
of hospice services to patients and families will be available
in
both English and Spanish. • United Hospice will form a planning
and outreach team
consisting of staff, volunteers and community members. This team
will provide support for the staff person assigned primary
responsibility for outreach effort. • United Hospice will host
listening sessions with Hispanic
community leaders, Hispanic clergy and other members of the
Hispanic community to develop an understanding of attitudes and
beliefs regarding end-of-life care.
• Based on listening sessions, United Hospice will develop a
message, presentation and marketing materials that address
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CON Action Numbers: 10069, 10070, 10071, & 10072
17
needs and issues expressed by focus group respondents to
ultimately deliver the message that addresses needs and
concerns of the community.
• United Hospice will continually assess existing tools and
obtain or develop new resources as needed to provide culturally
meaningful and appropriate educational opportunities for the
Hispanic community.
• The applicant will provide ongoing comprehensive training
for
staff and volunteers who are actively involved in the outreach
program. These individuals will plan quarterly town hall
meetings with members of the community to engage, educate and
energize individuals to begin end-of-life conversations in their
organizations, congregations and so forth.
• United Hospice will develop and maintain a calendar of
events
that address, support and celebrate Hispanic issues, heritage
and health care concerns. Staff members will attend various
calendar events with the goal of making United Hospice of
Florida the name and face known throughout the community. • The
applicant will develop a census tracking tool to routinely
track referrals generated by the outreach program to measure its
ongoing success.
• By the time of final CON approval, the United Hospice
website
will be available and accessible in the Spanish language.
• The applicant will report its admissions annually by ethnicity
to
measure success and increase in percentage of Hispanic
admissions. This condition will be measured by a signed
affidavit submitted to the Agency.
3. CHAP Accreditation – United Hospice has conditioned approval
of
this application on the provision it will seek and obtain
CHAP
accreditation upon certification. This will be measured by
submitting United Hospice's accreditation certificate to the
Agency
upon receipt.
4. Membership Organizations - Upon licensure, United Hospice
will
become a member of the following community organizations: •
Florida Hospice and Palliative Care;
• Hispanic Chamber of Commerce of Central Florida; • Orlando
Regional Chamber of Commerce; and
• Kissimmee/Osceola Chamber of Commerce;
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This will be measured by a signed affidavit submitted to the
Agency.
5. United Hospice Foundation - United Hospice Foundation will
make available to Florida residents, its annual scholarship program
targeted at those who are studying nursing, pharmacy or therapy
with an interest in end-of-life care. The scholarship is
available each year to four students in the amount of $2,000 for
the school year. This will be measured by a signed affidavit
submitted to the
Agency.
6. Office Locations – United Hospice will open two office
locations immediately upon licensure; at least one location will be
in a Hispanic area of Osceola County. A third office location will
open
in the third year of operation.
7. Staffing Ratios and Qualification – United Hospice will meet
or exceed all NHPCO Guidelines for qualifications and staffing
ratios for patient care staff. This will be measured by a
signed
declaratory affidavit submitted to the Agency. ALL: None of the
applicants proposed to condition to voluntary reporting
of the Agency‟s „Family Evaluation of Hospice Care (FEHC)
Satisfaction Survey‟ found at the FloridaHealthFinder.gov website.
Hospice programs
are required by federal and state law to provide services to
everyone requesting them and therefore the Agency would not place
conditions on a program to provide legally required services. Rule
59C-1.013(4) Florida
Administrative Code contains condition compliance reporting
criteria that the Agency uses for an approved CON that has
conditions.
D. REVIEW PROCEDURE
The evaluation process is structured by the certificate of need
review criteria found in Section 408.035, Florida Statutes, rules
of the State of
Florida, and Chapters 59C-1 and 59C-2, Florida Administrative
Code. These criteria form the basis for the goals of the review
process. The
goals represent desirable outcomes to be attained by successful
applicants who demonstrate an overall compliance with the criteria.
Analysis of an applicant's capability to undertake the proposed
project
successfully is conducted by evaluating the responses provided
in the application, and independent information gathered by the
reviewer.
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19
Applications are analyzed to identify various strengths and
weaknesses in each proposal. If more than one application is
submitted for the same
type of project in the same district (subdistrict or service
planning area), applications are comparatively reviewed to
determine which applicant
best meets the review criteria. Section 59C-1.010(2) b, Florida
Administrative Code, prohibits any
amendments once an application has been deemed complete. The
burden of proof to entitlement of a certificate rests with the
applicant. As such, the applicant is responsible for the
representations in the
application. This is attested to as part of the application in
the certification of the applicant.
As part of the fact-finding, the consultant, Cheslyn Green,
analyzed the application in its entirety with consultation from
financial analyst,
Everett Broussard, who evaluated the financial data.
E. CONFORMITY OF PROJECT WITH REVIEW CRITERIA
The following indicates the level of conformity of the proposed
projects with the criteria found in Florida Statutes, Sections
408.035 and 408.037; applicable rules of the State of Florida,
Chapter 59C-1 and
59C-2, Florida Administrative Code.
1. Fixed Need Pool
a. Does the project proposed respond to need as published by a
fixed
need pool? Chapter 59C-1.008, Florida Administrative Code and
Chapter 59C-1.0355, Florida Administrative Code.
In Volume 35, Number 39 of the Florida Administrative Weekly,
dated October 2, 2009, the Agency for Health Care Administration
published a
need for one hospice program in Hospice Service Area 7B for the
January 2011 Hospice Planning Horizon. Hospice Service Area 7B is
currently served by four licensed hospice providers: VITAS
Healthcare Corporation
of Florida, Hospice of the Comforter, Inc., Samaritan Care
Hospice, and Cornerstone Hospice and Palliative Care.
Each co-batched applicant is applying in response to published
need for a hospice program in Hospice Service Area 7B, Orange and
Osceola
Counties. However, all applicants provided additional arguments
in support of need for their projects as discussed below.
Catholic Hospice of Central Florida, Inc. (CON #10069) states
that Service Area 7B has experienced rapid population growth
between April
1, 2000 and April 2009, 32 percent compared to 19 percent in the
state
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CON Action Numbers: 10069, 10070, 10071, & 10072
20
as a whole. Within Osceola County the population increased by 62
percent. Orange County grew by 27 percent. Growth within service
Area
7B‟s Hispanic community was even more dramatic, according to the
applicant, increasing by 94 percent since 2000, nearly double
the
statewide growth rate of 51 percent. The applicant provides
percentages only for the majority of its population discussion,
actual population numbers are included when provided. The applicant
states that the April
2009 estimated service area population of 1,414,362, includes
425,505 Hispanic residents. Catholic Hospice indicates that Orange
County trails only Miami-Dade and Broward Counties in total number
of Hispanic
residents. Osceola County, with 43 percent Hispanic residents,
ranks third among all Florida counties while Orange County at 27
percent
ranks seventh in percent Hispanic residents. Overall, 30 percent
of 7B residents are Hispanic compared to 21 percent statewide. The
applicant states that rapid growth is projected to continue over
the next five years,
especially among Hispanics. Between April 1, 2009 and 2014, the
resident population of the service area is expected to increase by
12
percent as compared to eight percent in the state as a whole
with projected growth in Osceola County of 19 percent and 11
percent in Orange County. Hispanic population growth of 23 percent
is projected
within the service area as compared to 16 percent statewide. By
2014, the applicant states that Service Area 7B is expected to have
524,316 Hispanic residents, representing one-third (33 percent) of
the area‟s total
1.6 million population.3 The applicant concludes that demand for
hospice services should increase with population growth.
Catholic Hospice next discusses the Pew Foundation‟s Forum on
Religion and Public Life, U.S. Religious Landscape Survey of
February 2008 and
states that based on its research, the foundation estimates that
between 65 and 68 percent (roughly two-thirds) of the
Hispanic/Latino population is affiliated with the Catholic Church.
The applicant states it is
committed to providing hospice care oriented to the language,
cultural and religious beliefs of the Hispanic/Latino community.
The applicant
states that its sister organization Catholic Hospice, Inc.,
currently provides hospice care in Service Areas 10 and 11 which
along with Service Area 7B have the highest concentration of
Hispanic/Latino
residents in the state of Florida.
Catholic Hospice states that during calendar year 2008 Hispanics
accounted for 10 percent of all deaths in Service Area 10 and 58
percent of deaths in Service Area 11. By comparison, Hispanics
constituted 31
percent of the patients serviced by Catholic Hospice Inc, in
Service Area 10 and 78 percent of those served in Service Area 11.
The applicant states that it has a long standing commitment and
record of serving the
3 Catholic Hospice indicates that the population estimates are
based on the Florida Office of Economic
and Demographic Research (EDR) data.
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CON Action Numbers: 10069, 10070, 10071, & 10072
21
Hispanic Community and is ideally suited to addressing the
documented need for a new hospice program in Service Area 7B.
The applicant states that consistent with the low percentage of
elderly
residents within the service area, the proportion of deaths
accounted for by persons age 65 or older (65.9 percent) lags behind
the statewide average (74.1 percent). Persons age 85 and older use
hospice care
services at a higher rate than all other age groups. Within
Service Area 7B, persons in this advanced age category made up 25.3
percent of all deaths as compared to 31.0 percent of deaths among
all Florida
residents. The applicant contends that the low percentage of
deaths accounted for by elderly and extremely elderly residents
within Service
Area 7B implies hospice penetration rates below the statewide
rate. Catholic Hospice states that historically, non-Hispanic
whites have used
hospice services at a higher rate than other ethnic and racial
groups, including Hispanics, Black/African Americans, and persons
of
Asian/Pacific Island descent. During calendar year 2008, there
were 1,343 deaths among Hispanic residents of Service Area 7B
representing 16.3 percent of all service area deaths. By
comparison, Hispanics
accounted for 11.1 percent of all Florida resident deaths. The
same year there were 1,322 deaths to Black/African American
residents of the service area. These deaths make up 16.0 percent of
all resident deaths.
By comparison, African Americans accounted for 10.7 percent of
all Florida resident deaths.
Catholic Hospice contends that the high percentage of both
Hispanic and Black/African American deaths in the service area
leads to the
expectation of a hospice penetration rate below the statewide
rate. The applicant states that the hospice admissions and
admission rates may be depressed due to a high proportion of
sudden/unexpected deaths by
suicide, homicide, perinatal conditions, unintentional injury
(accidents) or other external causes. Catholic Hospice contends
that within the
service area, hospice appropriate deaths accounted for a
somewhat lower percentage of all resident deaths as compared to the
state as a whole (89.3 percent versus 91.7 percent). While the use
of hospice services had
grown among persons with non-cancer diagnoses, cancer patients
continue to make up a disproportionate share of all hospice
users.
Cancer patients accounted for 23.2 percent of service area
deaths in 2008 compared to 23.9 of all Florida resident deaths.
The applicant states that historically, higher rates of hospice
utilization have been found among higher income populations. Orange
County ($31,589) ranked above the Florida median county per capita
income of
$26,072 in 2005. However, the per capita income fell below the
2005 statewide average per capita income level $34,001. Per-capita
income in
Osceola County ($22,008) fell 35 percent below the statewide
average.
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CON Action Numbers: 10069, 10070, 10071, & 10072
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The applicant states that per capita income may exert downward
pressure on hospice utilization within some lower-income portions
of
Service Area 7B.
According to the applicant, between 2001 and 2008 hospice
admissions in Florida grew by 51 percent despite just a two percent
increase in resident deaths over that same period. Hospice
admissions in Service
Area 7B grew somewhat slower (46 percent) despite a much greater
increase in resident deaths (seven percent). As a result, Service
Area 7B‟s hospice admissions rate for calendar year 2008 (59.6
percent)
lagged behind the state median rate of 62.3 percent. The
applicant asserts that this lag in hospice admissions within 7B is
consistent with
the presence of various factors impeding hospice use, as
discussed above. Catholic Hospice concludes that these factors must
be addressed and overcome in order for hospice use rates to grow to
a level more
consistent with the true needs of the service area.
The applicant states that after sending out several members of
its staff to speak to members of the community, several concerns
were identified within the Osceola County area. The applicant
states that a local
hospital administrator identified a poor response time to
patients and families in need of immediate end-of-life care within
the Osceola County area, which the applicant states leads to the
perception of insensitivity to
patients and families as well as an inability to meet their
needs. The next concern as identified by area residents was a need
to have an
additional choice of hospice. The third area of concern voiced
by many residents was the need for a faith-based, not-for-profit
provider that would offer those patients and families that needed
to access hospice
care an alternative to the current providers. Catholic Hospice
states that its staff visited all skilled nursing facilities in
Kissimmee and it was very apparent there was a desperate need
for a hospice experienced in hospice services that meet the needs
of the
Hispanic population. The need for a hospice with bilingual staff
that speak Spanish in addition to English was also identified.
According to the applicant, concerns were also raised as to the
number of field staff
who are unable to communicate with the clients, residents and
patients for whom they are caring. The applicant also identified a
need for
children‟s grief counseling and bereavement services within the
service area. Catholic Hospice states that this should be in a
therapeutic environment such as a camp and amongst peers in order
to resolve grief
issues as well as to have grief issues identified by bereavement
professionals. The applicant states this is why the development of
the camp is a condition to this application.
The applicant cites Catholic Hospices‟ service to the
Hispanic
community, states that it has a mission of service to the
indigent and low
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CON Action Numbers: 10069, 10070, 10071, & 10072
23
income population and that it will make a concerted effort to
reach out to all segments of the service area‟s population.
Catholic concludes that its
market assessment affirms the Agency‟s finding of need for an
additional hospice program to serve Area 7B and hospice admissions
in the 2011
horizon year should equal or exceed the level forecast by the
Agency.
Catholic Hospice contends that its strengths will spur
utilization
throughout all segments of the population, particularly among
lower income and ethnic residents.
The applicant states that it will place its main office in
Kissimmee because the location addresses a variety of
considerations including: an
emphasis on service to the Hispanic community, the location of
existing hospice programs, access to the transportation network
serving the area and population size and projected growth within
the service area.
Catholic Hospice also states that three of the four have branch
offices in the Kissimmee area. The city of Kissimmee is centered in
zip code area
34741 which has the largest number of Hispanic residents (28,164
of 48,629 total or 58 percent) of any zip code within the service
area. Zip code area 34743 which includes the eastern terminus of
the city has
nearly as many total Hispanics (26,125) and the highest
percentage of Hispanic residents (26,125 of 38,079 total or 69
percent) within the service area. The second largest concentration
of Hispanics is in the
Union Park area of Orange County, east of downtown Orlando.
Hispanic Population by Zip Code Area: 2009 Within 10-mile radius
of Kissimmee
Area County Hispanic Total % Hispanic
32824 Orange 18,378 33,025 56%
32837 Orange 16,200 48,098 34%
32831 Orange 2,261 13,678 17%
34741 Osceola 28,164 48,629 58%
34743 Osceola 26,125 38,079 69%
34744 Osceola 17,008 42,162 40%
34746 Osceola 11,827 33,317 35%
34758 Osceola 14,631 30,910 47%
34769 Osceola 3,995 23,120 17%
138,589 311,018 45%
7B 397,649 1,419,409 28% Source: CON Application #10069, page
19.
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CON Action Numbers: 10069, 10070, 10071, & 10072
24
Hispanic Population by Zip Code Area: 2009
Union Park Area of Orange County Area County Hispanic Total %
Hispanic
32792 Orange 9,981 45,729 22%
32807 Orange 15,818 32,193 49%
32817 Orange 10,069 38,289 26%
32822 Orange 27,117 56,464 48%
32825 Orange 22,834 55,696 41%
32826 Orange 5,621 21,989 26%
32828 Orange 15,662 52,297 30%
107,102 302,657 35%
7B 397,649 1,419,409 28% Source: CON Application #10069, page
19.
Hispanics make up 40 percent of Kissimmee and Union Park
residents while only 19 percent of the service area population
outside these two areas is Hispanic. The applicant states that
while three of the four
existing 7B hospice programs maintain a satellite office in
Osceola County, all within the Kissimmee area, it would be the only
hospice program to establish Kissimmee as its primary office
location. The
applicant states that a primary office location in Kissimmee
will afford lower income residents a high level of access to the
full range of
community outreach and family support services it offers. Agency
records indicate that the three existing providers with branch
offices in Kissimmee are Hospice of the Comforter and VITAS in zip
code 34741
and Cornerstone in zip code 34744. The applicant does not
demonstrate that having a primary office in the same area that has
three branch offices within a 10-mile radius of Kissimmee would
have any impact on
the provision of hospice care.
Over the next five years, Kissimmee and the surrounding area is
projected to continue its rapid growth. The nine zip code area (as
previously defined) is expected to realize a 19.5 percent increase
in
population from January 2009 to January 2014. By comparison, the
previously defined Union Park area (which has the area‟s second
highest
concentration of Hispanic residents) is expected to grow by 11.5
percent. The remainder of the service area is projected to grow by
12.4 percent.
Projected Population Growth within 7B
January 2009 to January 2014 Difference
Area 2009 2014 # %
Kissimmee 311,018 371,803 60,785 19.5%
Union Park 302,657 337,603 34,946 11.5%
Other 7B 805,734 905,580 99,846 12.4%
7B 1,419,409 1,614,986 195,577 13.8% Source: CON Application
#10069, page 22.
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CON Action Numbers: 10069, 10070, 10071, & 10072
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The applicant states that the continuing trend of rapid
population growth in and around the city of Kissimmee lends added
support to its selection
of Kissimmee as its primary office location. As program needs
become established and patient census grows, a satellite office
will be developed.
The applicant states its first, second and third year admissions
are estimated at 161, 413, and 508 respectively. The first year‟s
market
share will be three percent, the second year share will be 7.5
percent and the third year share will be 9.0 percent. The following
is an illustration of projected admissions for the applicant in
Service Area 7B.
Projected Admissions for CHI in Service Area 7B
Based on the Hospice Rule Mortality Methodology and Inputs
Year 1 Year 2 Year 3 Year 4 CY 2011 CY 2012 CY 2013 CY 2014
July 1 Population 1,485,528 1,523,278 1,560,902 1,598,043
Under 65 1,337,443 1,368,055 1,398,382 1,428,110
65 and over 148,085 155,223 162,520 169,933
Estimated Deaths
Cancer Under 65 769 789 808 827
Cancer 65+ 1,370 1,405 1,440 1,474
Non-Cancer Under 65 2,370 2,430 2,490 2,549
Non-Cancer 65+ 4,512 4,626 4,741 4,853
All Diagnoses, All Ages 9,021 9,250 9,479 9,704
Penetration Rates
Cancer under 65 92.0% 92.0% 92.0% 92.0%
Cancer 65+ 93.7% 93.7% 93.7% 93.7%
Non-Cancer under 65 21.3% 21.3% 21.3% 21.3%
Non-Cancer 65+ 63.8% 63.8% 63.8% 63.8%
All Diagnoses, All Ages 59.6% 59.6% 59.6% 59.6%
Hospice Admissions
Cancer under 65 708 726 744 761
Cancer 65+ 1,284 1,317 1,349 1,381
Non-Cancer under 65 505 518 530 543
Non-Cancer 65+ 2,878 2,952 3,024 3,096
All Diagnoses, All Ages 5,537 5,513 5,647 5,781
Market Share
Catholic Hospice 3.0% 7.5% 9.0% 11.0%
Others 97.0% 92.5% 91.0% 89.0%
Total 100% 100% 100% 100%
Admissions by Program
Catholic Hospice 161 413 508 636
Others 5,214 5,100 5,139 5,145
Total 5,375 5,513 5,647 5,781
Source: CON Application #10069, page 23.
The applicant states that the annual patient admissions for its
proposed
program is based primarily on: the aggregate experience of
hospice programs initiating operations in Florida since the
beginning of calendar year 2002 and the size of the Service Area 7B
market.
The applicant asserts that projected growth in hospice
admissions within
the service area is sufficient to achieve its goal of building a
viable new program within the area, while also allowing existing
hospice programs to continue growing their admissions.
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CON Action Numbers: 10069, 10070, 10071, & 10072
26
Memorial Hospital Flagler, Inc. d/b/a Florida Hospital
HospiceCare (CON #10070) proposes to establish a hospice program in
Service Area
7B and to open two offices in the first year of operations. One
office will be in Osceola County on the campus or in proximity to
Florida Hospital
Kissimmee. The applicant states that the other office will be
located in Orange County on the campus or in proximity of an Orange
County facility to best suit the needs of the (Florida Hospital)
Clinical Pastoral
Education, Medical Education and Palliative Care programs.
Florida Hospital HospiceCare indicates that there are several
characteristics that distinguish it from existing providers and
other applicants, which makes it the best applicant to meet the
published need
and serve as a complement to existing hospice providers. These
include its mission, chaplaincy and pastoral care, integration and
continuum of care, and medical education for physicians, residents
and other health
professionals.
In discussion of its mission, the applicant indicates that there
are six principles that Adventist Health System draw motivation and
direction to guide how employees and patients are treated. These
are:
Christian Mission - We serve the needs of our communities in
harmony with Christ‟s healing ministry and incorporate Christian
values at every level of service.
Quality and Service Excellence - We meet or exceed both the
service
standards of the health care industry and the expectations of
the patients we serve and measure through continuous surveying
of
patient satisfaction.
Compassion – We are sensitive to the needs of the individuals
and
families we serve and meet their needs with kindness and
empathy.
Focus on Community Wellness – We commit time, talent and
financial
support to educate our neighbors in the principles of illness
prevention and healthful living.
High Ethical Standards – We conduct business with integrity,
honesty and fairness. As responsible stewards, we use our financial
resources
wisely by choosing business practices which are cost-effective,
productive and result in a fair return on investment.
Cultural Diversity – We value the diversity of our patients,
employees,
business colleagues and visitors and treat them with kindness
and respect regardless of their background, race, religion or
culture.
The applicant indicates that Florida Hospital HospiceCare
provides
hospice services consistent with its mission statement and this
program will complement other services through education concerning
hospice within the organization and promote timely referral of
patients.
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CON Action Numbers: 10069, 10070, 10071, & 10072
27
In reference to chaplaincy and clinical pastoral education, the
applicant indicates that Florida Hospital is one of 13 Clinical
Pastoral Education
(CPE) programs in Florida and one of two in SA 7B that is
accredited by the Association for Clinical Pastoral Education
(ACPE). ACPE is a 2,600
member group that includes 350 ACPE accredited CPE Centers and
600 ACPE-certified faculty members (called CPE supervisors). There
are 113 Theological Schools Members and 23 Faith Groups and
Agencies who
partner with ACPE in seeking to provide excellence in
theological education. Asbury Theological Seminary is the ACPE
accredited theological school in SA 7B and is described as an
institution in the
Wesleyan tradition that collaborates with the Florida Hospital
CPE
Center. The Florida Hospital CPE Center is stated to provide
several programs including:
Full-time, one-year ACPE-accredited residency (currently eight
full-time residents),
Part-time, six-month ACPE-accredited residency (35 residents per
semester, 70 per year),
ACPE-accredited training for CPE supervisors,
An intensive 11-week unit of CPE during the summer months
which
is open to clergy, laity, religious workers, and students for
the ministry; designed to integrate personal, interpersonal and
professional learning in ministry formation,
A summer program offered at Florida Hospital East Orlando in
conjunction with the Asbury Seminary Latino/Latina Studies
Program (LLSP); the entire program is conducted in Spanish
language,
Programs and resources to community organizations - Association
of Professional Chaplains, Andrews University (Adventist university
and
seminary in Orlando), and many others,
Continuing education for ministry and training for
institutional
chaplains. FloridaHospice Care indicates that hospice care
represents a natural
extension of the pastoral care provided by Florida Hospital
chaplains.
In reference to the integration and continuum of care as an
existing provider the applicant indicates that:
As a hospital-based applicant for a hospice program,
FloridaHospice Care will be an integrated part of Adventist/Sunbelt
and Florida Hospital. Florida Hospital has provided health care to
residents of central Florida
for over 100 years, earning a reputation of excellence and the
trust of patients and physicians. As a trusted provider of care
across the entire
service continuum, Florida Hospital is well-positioned to inform
and raise
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awareness of the benefits of hospice care. Six Florida Hospital
acute care and two Adventist Care Center skilled nursing facilities
provide
geographic coverage to residents of Orange and Osceola
Counties:
Florida Hospital Orlando, a state-of-the-art 1,080-bed facility
located in Orlando in Orange County, is the largest of the six
Florida Hospital
facilities in Service Area 7B.
Florida Hospital Orlando is an accredited Community
Comprehensive
Cancer Center, provides organ transplant services, open heart
and other state-of-the-art cardiovascular surgery, behavioral
health,
orthopedic, and rehabilitation services, comprehensive services
and education in a Diabetes Center, and other inpatient and
outpatient services along the continuum of care.
The applicant‟s integration and continuum of care discussion
included
Table 1 on page nine of the application which documented
individual Florida Hospital facilities discharge volume. Florida
Hospital facilities discharged 66,238 Service Area 7B residents
(excluding normal
newborns) during the 12 months ending June 2009. The applicant
contends that a hospice program affiliated with a hospital is more
likely
to increase awareness of hospice as an option and to maximize
the resources available within the health care system, particularly
with residents who do not have cancer. The applicant cites a 2001
National
Hospice & Palliative Care Organization and the Center for
Palliative Care, study entitled “Hospital-Hospice Partnerships in
Palliative Care: Creating a Continuum of Service” as support for
its project. Page 11 of the
application includes the following summary of the benefits of
integration Florida Hospital HospiceCare contends apply to this
project.
Benefits of Collaboration for Hospital and Hospice Partners For
the Hospital: Improve the quality of care for hospitalized
seriously and terminally ill
patients and their families.
Learn more about the nature and value of hospice services,
including psychosocial, spiritual, and bereavement components and
the functioning of the hospice interdisciplinary team.
Launch palliative care and end-of-life services in collaboration
with an experienced provider.
Improve continuity of care with post-hospital settings.
Utilize training opportunities for staff.
Affiliate with hospice's positive community image and
philanthropic success.
Draw upon a new avenue of reimbursement (the Medicare Hospice
Benefit) for terminally ill hospitalized patients.
Improve resource utilization for seriously ill patients and
reduce the costs of their care, according to recent research.
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29
For the Hospice: Access more patients who will benefit from
hospice care earlier in the course
of a terminal illness.
Learn more about the challenges and practice of end-of-life care
in the acute care setting.
Gain access to the organizational resources of the hospital.
Learn more about inpatient palliative care treatments.
Establish new or improved organizational linkages to larger
health systems.
Participate in palliative care expansion by applying knowledge
and expertise to a setting where many patients with
life-threatening illnesses receive their care.
Integrate hospice services within a broader continuum of
palliative care.
Achieve more appropriate and timely referrals through
participation in the
broader continuum.
Clinical Benefits of a Hospital-based Palliative Care Program
For the Patient:
Reduction in symptom burden.
Care concordant with patient-family preferences.
Patient-family-professional consensus on the goals of medical
care.
Improved patient and family satisfaction.
The applicant states that approval of Florida Hospital
HospiceCare will
benefit the overall health care system in several ways:
Heightened awareness of hospice as an option for care for
patients
throughout the continuum of care, including with patients with
partnering community organizations and other health care
providers;
Potentially earlier placements in hospice care; and
Increased educational opportunities for physicians, medical
residents,
and other health care providers.
However, many of these benefits could be obtained by hospice and
hospital collaboration regardless of the licensure relationship
between the two entities.
In reference to medical education for physicians, residents and
other
health professionals, the applicant notes that Florida Hospital
is a statutory family practice teaching hospital with residencies
in family practice and surgery and fellowships in geriatric
medicine and
gynecological oncology. The applicant indicates that Florida
Hospital is uniquely qualified to provide ongoing education and
communication
about this important service (hospice) to these physicians in
training. Florida Hospital‟s teaching program is described and the
applicant indicates that it will initiate a comprehensive and
ongoing physician
education program targeted to providing information and ease of
access to the physicians in Orange County and specifically those on
staff at
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30
Florida Hospital‟s Orange and Osceola hospitals. Education
topics will include „Death, Dying and Bereavement‟, „Hospice 101‟,
„Hospice
Eligibility Requirements‟ and „Spiritual Considerations at the
End of Life‟. The applicant indicates that these programs will be
expanded to meet the
educational and training needs of health care professional
students. The applicant also contends that there are additional
Florida Hospital
HospiceCare attributes and qualifications that distinguish its
application. These include the following:
Florida Hospital HospiceCare has a history of providing
excellent
services for patients and their families, including proven
practices and policies and a compassionate understanding of the
nature of hospice
care.
Florida Hospital HospiceCare will provide a volunteer service
that is
integrated with the community, leveraging the success of Florida
Hospital and Florida Hospital HospiceCare in recruiting and
utilizing
community volunteer resources.
Florida Hospital HospiceCare will develop a Community
Advisory
Board once the application is approved to appropriately guide
program and service development.
Florida Hospital HospiceCare and related entities have in-place
the
resources and infrastructure needed to successfully implement
the hospice service in Service Area 7B.
Referral relationships with area physicians, post-acute
providers, community organizations, and charities;
Agreements for inpatient care needed by hospice patients will be
entered into with one or more Florida Hospital facilities in
Service
Area 7B (Florida Hospital Apopka, Florida Hospital Celebration
Health, Florida Hospital East Orlando, Florida Hospital Kissimmee,
Florida Hospital Orlando, and Winter Park Memorial Hospital),
the
Adventist Care Center skilled nursing facilities, as well as
other area providers; and
Support and billing cycle services, recruiting, and staff
training, and other administrative services will be provided by the
existing offices of
Florida Hospital HospiceCare. Florida Hospital HospiceCare will
provide services that go beyond the Medicare Hospice Benefit.
Florida Hospital HospiceCare concludes that it provides
excellent and compassionate hospices services in Service Area 4B
and is the best
applicant to meet the identified need in Service Area 7B. The
applicant next provides a discussion of Service Area 7B.
The applicant states that Service Area 7B had an estimated
population of 1,420,611 residents in 2009 and is projected to grow
rapidly to a population of 1,598,043 residents by 2014,
representing an increase of
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12.5 percent. Both counties have a relatively young population,
with the proportion of elderly residents (age 65 and over) in
Orange County
projected to be 10.3 percent of the total population and 11.8
percent in Osceola County in 2014.
The applicant contends that the growth in the Hispanic
population in Service Area 7B has been significant. In Orange
County, the Hispanic
population grew from 18.8 percent of the total population in
2000 to 26.4 percent in 2008. In Osceola County, the number of
Hispanic residents doubled during the period, from 50,727 in 2000
to 121,599 in 2008. The
applicant contends that as a result, Hispanic residents as a
percent of total population increased in Osceola County from 29.4
percent in 2000
to 44.5 percent in 2008 and increased in Service Area 7B from
20.5 percent to 29.9 percent during the same time period. The
applicant states that although the Hispanic population is younger
than the overall
population, the number of Hispanic elderly residents increased
in Service Area 7B from 13,762 in 2000 to 27,840 in 2008.
HospiceCare contends
that the increase in Hispanic population presents a growing need
for a hospice that can accommodate residents of diverse ethnic
backgrounds, provide bilingual programs and culturally sensitive
programming to serve
this population. The applicant states that the Hispanic
population in Service Area 7B meets the definition of a special
needs population.
HospiceCare states that mortality in Service Area 7B increased
from 2000 to 2008 by a total of 9.8 percent. Although Hispanics
make up a
small percentage of total deaths that occur within Service Area
7B (7.2 percent in 2000 and 16.3 percent in 2008), the number of
deaths increased by 149.2 percent compared to population growth of
91.0
percent during this period4. The applicant contends that while
the number of deaths in Service Area
7B has been relatively stable over the past few years, HIV/AIDS
deaths remained fairly consistent except for a brief increase in
2003. The 122
cases of HIV/AIDS deaths in the service area for 2003 were
relatively higher than what has been experienced in recent years.
HospiceCare states that while the number of deaths caused by
HIV/AIDS is not large,
it does represent a segment of the population who are more
likely to utilize hospice services. HospiceCare states that another
area of focus
has been patients with Alzheimer‟s disease and has therefore,
developed their program to include strategies for providing
traditional palliative care to patients suffering from the
disease.
4 Tables 6 and 7, CON Application #10070, pages 34 and 35:
Service Area 7B Deaths by Age and
Ethnicity, 2000 to 2008.
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The applicant provides analysis of historical utilization of
hospice services in Florida and Service Area 7B. There are
currently four hospice
providers in Service Area 7B, Cornerstone Hospice and Palliative
Care, Inc., Hospice of the Comforter, Inc., Samaritan Care Hospice,
and VITAS
Healthcare Corporation of Florida. Analysis in this section
includes number of admissions by category and age over a two year
period for each existing hospice provider. The applicant reports
that for the twelve
months ending June 2009 in Service Area 7B Cornerstone had 638
admissions, Hospice of the Comforter 1,882, Samaritan 485, and
VITAS had 1,886 admissions.
HospiceCare states that it is confident that it can manage a
hospice
program in Service Area 7B that satisfies community needs.
HospiceCare states it projected its future hospice utilization
using the guidelines and methodology in the hospice rule. An
average death rate of
0.006073 was calculated for 2005 through 2007, and then used to
project deaths for years 2010 to 2011. The applicant states the
result is
a need for 484 additional hospice admissions for the January
2011 Planning Horizon. The applicant states the next step was to
apply the three-year death rates to the projected population for
2010 to 2011 to
project deaths by disease category and age. The methodology
results in a net need for 484 admissions, which according to the
applicant is conservative in projecting need since it assumes
constant hospice
penetration rates which have historically increased 5. The
applicant contends that based on the Agency‟s hospice need
methodology, Service
Area 7B residents who do not have cancer are projected to have
an unmet need of 259 hospice admissions in 2011. In addition,
residents under 65 without cancer were projected to have an unmet
need of 174
admissions in 2011. The applicant‟s need projections are
consistent with the Agency‟s publication for this batch as revised
on October 13, 2009.
HospiceCare contends it will meet the need identified for
residents of Service Area 7B. It will achieve market shares between
5.3 and 7.6
percent, resulting in projected utilization of 280 admissions in
2010 and 410 in 20116. The applicant states it will achieve its
utilization without substantial impact on the existing hospice
providers in the area.
Odyssey HealthCare of Collier County, Inc., d/b/a Odyssey
HealthCare of Central Florida, (CON #10071) proposes to
establish a hospice program in Service Area 7B. The applicant
states that based on the market forecast there is adequate hospice
volume growth in Hospice
Area 7B to maintain the four existing hospice programs at
current
5 Tables 10 and 11, pages 39 and 40, CON Application #10070:
Historical Population and Deaths by
Cause/Age 2005-2007 and Projected Utilization for HospiceCare
Service Area 7B. 6 Table 14, page 42, CON Application #10070:
Projected Market Share for HospiceCare Service Area
7B.
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CON Action Numbers: 10069, 10070, 10071, & 10072
33
volume levels while at the same time providing adequate new
incremental hospice volume to establish a viable new hospice
provider. The applicant
states that in addition to the Agency identified need it will
present evidence of the existence of special and not normal
circumstances in the
hospice system that also demonstrate the need for the proposed
hospice program in Service Area 7B to better serve area residents
in need of hospice services.
The applicant states its hospice will be located in Orange
County within Service Area 7B and will establish a satellite office
in Osceola County by
the end of year one of operation. The 2009 total population of
Hospice Service Area 7B accounts for 59 percent of the District 7
total population
(1,420,611/2,418,538). From 2009 to 2012 the hospice service
area population is projected to grow from 1,420,611 persons in 2009
to 1,523,278 persons in 2012; an increase of 102,667 persons or
7.2
percent during this three year period.
The percentage increase in total population is well above the
growth rates District 7 (6.2 percent) and the State of Florida (4.9
percent). The applicant states that while the projected growth in
the total population is
important, a more important consideration is the projected
population of the older age cohorts of the service area population
which are most likely to use hospice services. The older age
cohorts will experience a greater
percent increase in population than the younger age cohorts or
the population as a whole. Hospice Service Area 7B is home to a
significant
proportion of persons‟ age 65 years and older: 45 percent of
District 7‟s 65 and older population live in Hospice Service Area
7B. Hospice Service Area 7B population age 65 and older will
increase by 18,414 persons
(+13.5 percent) between 2009 and 2012; a growth rate well above
the 7.2 percent growth forecast for the population as a whole. The
increase of 18,414 persons represents 50.5 percent of the total
increase in the
number of persons‟ age 65 years and older in District 7
(18,414/36,447).
The applicant states that an effective Hospice Service Area 7B
hospice provider must be able to support and provide care to a wide
array of patients groups with unique needs and service
requirements. Cancer
accounted for the largest number of deaths in Hospice Service
Area 7B (23.3 percent), closely followed by heart disease
accounting for 22.8
percent of deaths. The applicant states it has the ability and
experience base to treat all patients in need of hospice care and
is prepared to do so in Hospice Service Area 7B. In addition to the
gross number of deaths by
cause, providing an estimate of the potential pool of patients
for the proposed hospice program, the applicant also profiled
chronic disease mortality in the service area comparing the
age-adjusted death rates for
the service area versus the State of Florida. The age-adjusted
mortality rates provide an estimate of the patients who eventually
succumb to
these chronic diseases and therefore, a more accurate estimate
not only
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CON Action Numbers: 10069, 10070, 10071, & 10072
34
of the potential pool of patients, but also the range of
diagnosis of patients eligible for hospice services. The applicant
states that its
assessment of chronic disease mortality shows that both Osceola
and Orange Counties have rates well above Florida levels for
coronary heart
disease,