STATE OF ILLINOIS HEALTH FACILITIES AND SERVICES REVIEW BOARD 5 525 WEST JEFFERSON ST. SPRINGFIELD, ILLINOIS 62761 (217) 782-3516 FAX: (217) 785-4111 DOCKET ITEM: A-1 BOARD MEETING: December 10, 2012 PROJECT NUMBER: 08-082 PERMIT HOLDER(S): Rest Haven Illiana Christian Convalescent Home, Inc. FACILITY NAME and LOCATION: Victorian Village, Homer Glen STATE AGENCY REPORT SECOND PERMIT RENEWAL REQUEST I. Background On September 1, 2009, the State Board approved Project #08-082. The permit authorized the establishment of a 50-bed skilled nursing facility in 39,030 GSF of space in Homer Glen. The State Agency notes the project is obligated, and the current project completion date is December 31, 2012. II. Findings The State Agency notes the permit holders submitted the permit renewal request on November 8, 2012. This submittal was in accordance with 77 IAC 1130.740(d), which states that renewal requests must be received by the State Agency at least 45 days prior to the permit expiration date. A $500.00 permit renewal fee accompanied the renewal request. Board Staff notes this is the permit holders second permit renewal request, and the obligation period was extended 12 months on March 15, 2011. The permit holders initially requested a sixteen month permit renewal from August 31, 2011, to December 31, 2012, and this second request seeks to extend the project completion date from December 31, 2012, to February 28, 2014 (14 months). III. The Permit Renewal Request A. Requested Completion Date: The permit holders request a completion date of February 28, 2013. This would extend the project’s completion date by fourteen months, from December 31, 2012, to February 28, 2014. Page 1 of 37
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STATE OF ILLINOIS
HEALTH FACILITIES AND SERVICES REVIEW BOARD
5 525 WEST JEFFERSON ST. SPRINGFIELD, ILLINOIS 62761 (217) 782-3516 FAX: (217) 785-4111
DOCKET ITEM: A-1
BOARD MEETING: December 10, 2012
PROJECT NUMBER: 08-082
PERMIT HOLDER(S): Rest Haven Illiana Christian Convalescent Home, Inc.
FACILITY NAME and LOCATION: Victorian Village, Homer Glen
STATE AGENCY REPORT
SECOND PERMIT RENEWAL REQUEST I. Background
On September 1, 2009, the State Board approved Project #08-082. The permit authorized the establishment of a 50-bed skilled nursing facility in 39,030 GSF of space in Homer Glen. The State Agency notes the project is obligated, and the current project completion date is December 31, 2012.
II. Findings
The State Agency notes the permit holders submitted the permit renewal request on November 8, 2012. This submittal was in accordance with 77 IAC 1130.740(d), which states that renewal requests must be received by the State Agency at least 45 days prior to the permit expiration date. A $500.00 permit renewal fee accompanied the renewal request. Board Staff notes this is the permit holders second permit renewal request, and the obligation period was extended 12 months on March 15, 2011. The permit holders initially requested a sixteen month permit renewal from August 31, 2011, to December 31, 2012, and this second request seeks to extend the project completion date from December 31, 2012, to February 28, 2014 (14 months).
III. The Permit Renewal Request
A. Requested Completion Date: The permit holders request a completion date of February 28, 2013. This would extend the project’s completion date by fourteen months, from December 31, 2012, to February 28, 2014.
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B. Status of the Project and Components Yet to be Finished: The permit holders state the construction phase of the project has not commenced, and following items have been completed:
Zoning approval from the Village Board Architectural drawings approved by IDPH Design Standards Unit on
September 4, 2012. The following items remain to be completed:
Attainment of project financing (financing approval expected prior to December 10, 2012 IHFSRB meeting)
Construction, IDPH inspection, licensing
C. Reason(s) Why the Project Has Not Been Completed: The permit holders’ state the following events occurred, which delayed completion of the project: Immediately after project approval, financing for construction projects became more difficult, and the ability to finance under favorable terms almost impossible. The applicants, under direction of financial advisors, requested to delay the project until these conditions improved.
D. Evidence of Financial Commitment to Fund the Project: The permit holders
indicate $756,964 (7% of the total project cost) has been expended to date.
E. Anticipated Final Cost of the Project: The permit holders estimate the final cost of the project will be within the permit amount of $10,697,539.
IV. Project Description & Other Background Information
The permit authorized the establishment of a 50-bed skilled nursing facility as part of an assisted living/independent living facility in Homer Glen. The skilled nursing facility will contain 39,030 GSF and have an estimated project cost of $10,697,539. Permit Issuance Date: September 1, 2009
Original Project Completion Date: August 31, 2011 Extended Project Obligation Date: March 1, 2012 Project Obligation Date: March 23, 2012 Extended Project Completion Date: December 31, 2012 (first renewal request, 16 months)
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Extended Project Completion Date: February 28, 2014
(second renewal request, 14 months) V. Applicable Rules for Permit Renewal Requests
77 IAC 1130.740 specifies that a permit holder may request a change in the approved project completion date by applying for a permit renewal. 77 IAC 1130.740(b) states that failure to complete a project or to renew a permit within the prescribed timeframes will subject the permit holder to the sanctions and penalties provided in the Act and this Subpart. 77 IAC 1130.740(c) states that a permit renewal will commence on the expiration date of the original or renewed completion period. 77 IAC 1130.740(d) states that the State Board must be in receipt of a permit renewal request at least 45 days prior to the expiration date of the completion period, and include the following: 1) the requested completion date; 2) a status report on the project detailing what percent has been completed and a summary of project components yet to be finished and the amount of funds expended on the project to date; 3) a statement as to the reasons why the project has not been completed; and 4) confirmatory evidence by the permit holder’s authorized representative that the project’s costs and scope are in compliance with what the State Board approved and that sufficient financial resources are available to complete the project. 77 IAC 1130.740(e) states IDPH will review the request and prepare a report of its findings. If the findings are that the request is in conformance with all HFPB criteria, and if this is the first request for this project, then the request, IDPH’s findings, and all related documentation shall be sent to the Chairman. The Chairman, acting on behalf of HFPB, will approve, deny or refer the request to the HFPB for action. If IDPH finds that all criteria are not positive or, if this is not the first request for this project, or if the Chairman refers this to HFPB for action, then HFPB will evaluate the information submitted to determine if the project has proceeded with due diligence (as defined in 77 IAC 1130.140). Denial of a permit renewal request constitutes HFPB’s Notice of Intent to Revoke a permit and the permit holder will be afforded an opportunity for an administrative hearing.
VI. Other Information
Appended to this report are the following: the permit holders’ documents for a second permit renewal, the permit holders’ documents for the first permit renewal, and a copy of the Original State Agency Report.
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DOCKET NO:
A-9
BOARD MEETING:
March 10-11, 2009
PROJECT NO:
08-082
FACILITY NAME: Victorian Village
CITY: Homer Glen
PROJECT COST: Original: $10,697,539 Current:
TYPE OF PROJECT: Substantive HSA: IX
PROJECT DESCRIPTION: The applicant proposes to construct a 50-bed skilled care facility, with 39,030 gross square feet, which will be part of a continuum of care retirement community. The total estimated project cost is $10,697,539.
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Victorian Village
Homer Glen, Illinois Project #08-082
I. The Proposed Project
The applicant propose to construct a 50-bed skilled care (“LTC”) facility, with 39,030 gross square feet (“GSF”), which will be part of a continuum of care retirement community (“CCRC”). The total estimated project cost is $10,697,539.
II. Summary of Findings
A. The State Agency finds the proposed project appears not to be in conformance with the provisions of Part 1110.
B. The State Agency finds the proposed project appears not to be in
conformance with the provisions of Part 1120. III. General Information
The applicant is Rest Haven Illiana Christian Convalescent Home d/b/a Rest Haven Christian Services. The facility will be located at 12565 West Renaissance Circle, Homer Glen, Illinois in HSA IX and the Will County LTC planning area. The applicant owns the land for the proposed project and will be the operating entity/licensee. The January 2009 update to the State Board’s Inventory of Long-Term Care Services and Need Determination (“Inventory”) for the Will County LTC planning area shows a need for 311 LTC beds.
APPLICATION SUMMARY
Applicants Rest Haven Illiana Christian Convalescent
Home d/b/a Rest Haven Christian Services Facility Name Victorian Village
Location Homer Glen, Illinois Application Received October 10, 2008
Application Deemed Complete October 14, 2008 Scheduled Review Period Ended February 11, 2009
Review Period Extended by the State Agency?
No
Public Hearing Held? No Applicants’ Deferred Project? No
Can Applicants Request Another Deferral? No Applicants’ Modified the Project? No
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State Agency Report Project #08-082 Page 3 of 25
An opportunity for a public hearing was offered on this project; however, no hearing was requested. The applicant supplied two letters of support as part of the application for permit. No letters of support or opposition were received by the State Agency during the review period regarding this project. Per 77 IAC 1110.40; the project is classified as a substantive project and is subject to both a Part 1110 and Part 1120 review. The applicants are before the State Board because the project proposes the establishment of the long term category of service. Project obligation is to occur after permit issuance with an anticipated project completion date of August 31, 2010. The State Agency notes there are 164 LTC facilities located within a 30-minute travel time of the proposed site. Table One lists LTC providers within 30-minute travel time, their authorized beds, occupancy rates for 2007 and their distance and travel time from the proposed facility. The State Agency notes authorized beds and occupancy data were obtained from IDPH’s 2007 LTC profiles; while distance and travel times were determined using Map Quest. The information in the table is sorted based on time from the applicants’ proposed site. The State Agency further notes that the State Board’s target occupancy for LTC facilities is 90%.
TABLE ONE LTC Facilities within 30 Minutes Travel Time
Facility City Time Adjusted Distance Occupancy% Lemont Nrsg & Rehab Center Lemont 9 10.4 5 89.20%
Holy Family Villa Lemont 9 10.4 4.4 97.80%
Lexington Health Care Center Orland Park 10 11.5 4.4 85.00%
Alden-Orland Park Rehab & Hcc Orland Park 11 12.7 6.7 73.00%
Franciscan Village Lemont 12 13.8 6.9 91.00%
Manor Care - Palos Hgts West Palos Heights 15 17.3 7.5 88.20%
Hillside Rehab & Care Center Yorkville 51 58.7 32 79.90%
Walnut Grove Village Morris 51 58.7 41.5 90.60%
The State Agency notes authorized beds and occupancy data were obtained from IDPH’s 2007 LTC profiles; while distance and travel times were determined using Map Quest.
IV. The Proposed Project - Details
The applicant proposes to construct a 50-bed skilled care facility, with 39,030 gross square feet at a cost of $10,515,763, which will be part of a continuum of care retirement community. The CCRC has approximately 200 residents, a 54-unit independent living facility, a 60-unit assisted living care facility, 65 town homes, and an inn. The facility is being designed to implement the “small house” or “green house” concept of care to provide a homelike setting with three inter-
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related buildings. Thirty LTC beds will be in a 2-story building with 15 beds per floor, and 20-beds will be in two one story buildings each containing 10 LTC beds for those with more long-term needs. The project also includes minor modernization for the independent and assisted living facilities on the same camps.
V. Project Costs and Sources of Funds
The total estimated project cost is $10,697,539 and is to be totally funded from cash and securities, and a mortgage. Table Two displays the total cost information as well as cost information for the project’s components.
TABLE TWO Project Costs and Sources of Funds
Use of Funds LTC Non-Clinical
Total
Preplanning $44,000 $0 $44,000 Site Survey and Soil Investigation $25,000 $0 $25,000 Site Preparation $301,000 $12,000 $313,000 Off Site Work $40,000 $0 $40,000 New Construction Contracts $6,481,033 $143,170 $6,624,203 Contingencies $599,496 $0 $599,496 Modernization 0 $7,000 $7,000 Architectural/Engineering Fees $397,500 $7,500 $405,000 Consulting and Other Fees $422,422 $0 $422,422 Movable or Other Equipment $375,365 $0 $375,365 Loan Origination Fee $227,216 $3,905 $231,121 Net Interest Exp During Construction $477,152 $8,200 $485,352 Other costs to be capitalized $1,125,580 $0 $1,125,580 Total Project Cost $10,515,763 $181,775 $10,697,539
Sources of Funds Cash and Securities $2,139,508 Mortgage $8,558,031 Total Project Funds $10,697,539
VI. Cost Space Requirements
Table Three reflects the proposed project’s cost and space requirements. Modernization costs or vacated space are not included as part of this project.
A. Criterion 1110.320(a) Establishment of Additional Hospitals
This criterion is not applicable because the applicants are not proposing to establish a hospital. THE STATE AGENCY FINDS THE ESTABLISHMENT OF ADDITIONAL HOSPITALS CRITERION (77 IAC 1110.320 (a)) IS NOT APPLICABLE TO THIS PROJECT
B. Criterion 1110.320(b) Allocation of Additional Beds The criterion states: “The applicants proposing to establish a category of service must document that access to the service will be improved. Documentation shall consist of at least one of the following: 1) the proposed service is not available within the planning area; 2) existing facilities have restricted admission policies resulting in access limitations; 3) existing service providers are experiencing occupancy levels in excess of the category of service target levels; 4) the travel time to existing service providers is excessive (exceeds 45 minutes) for area residents to be served by the project.” As noted in Table One, the LTC service is available in the planning area. Thus, the applicants cannot meet the requirements of B)1) of the criterion. No information was submitted to document that existing facilities have restrictive admission policies. Thus, the applicants cannot meet the requirements of B)2) of the criterion. There are 164 LTC facilities located within a 30-minute travel time
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of the proposed site. For 2007, there are 113 LTC providers that did not achieve the State Board’s target occupancy of 90%. Thus, the applicants cannot meet the requirements of B)3) and B)4) of the criterion. The applicant does not meet the requirements of this criterion. THE STATE AGENCY FINDS PROPOSED PROJECT DOES NOT MEET THE REQUIREMENTS OF THE ALLOCATION OF ADDITIONAL BEDS CRITERION (77 IAC 1110.320 (b)
B. Criterion 1110.320(c) Addition of Beds to Existing Facilities
This criterion is not applicable because the applicants propose the establishment of a new facility. THE STATE AGENCY FINDS THE ADDITION OF BEDS TO EXISTING FACILITIES CRITERION (77 IAC 1110.320(c)) IS NOT APPLICABLE TO THIS PROJECT.
VIII. General Long-Term Care Review Criteria
A. Criterion 1110.1730(a) - Facility Size
The criterion states: “The maximum size of a general long-term care facility is 250 beds, unless the applicant documents that a larger facility would provide personalization of patient care and documents provision of quality care based on the experience of the applicant and compliance with IDPH's licensure standards (77 Ill. Adm. Code: Chapter I, Subchapter c) (Long-Term Care Facilities) over a 2 year period of time.”
The applicants propose a facility with 50 LTC beds, which is below the maximum standard of 250 beds.
THE STATE AGENCY FINDS THE PROPOSED PROJECT MEETS THE
REQUIREMENTS OF THE FACILITY SIZE CRITERION (77 IAC 1110.1730 (a))
B. Criterion 1110.1730(b) - Community Related Functions
The criterion states: “The applicant must document cooperation with and the receipt of the
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endorsement of community groups in the town or municipality where the facility is or is proposed to be located, such as, but not limited to, social, economic or governmental organizations or other concerned parties or groups. Documentation shall consist of copies of all letters of support from such organizations.” Within the application, the applicant provided ten letters of support from legislators, healthcare providers, and churches. Numerous letters of support from individuals were also included in the application for permit submittal. The applicants have met the requirements of this criterion.
THE STATE AGENCY FINDS THE PROPOSED PROJECT MEETS THE REQUIREMENTS OF THE COMMUNITY RELATED FUNCTIONS CRITERION (77 IAC 1110.1730 (b))
C. Criterion 1110.1730(c) - Zoning
The criterion states: “The applicant must document one of the following: 1) the property to be utilized has been zoned for the type of
facility to be developed; 2) zoning approval has been received; or 3) a variance in zoning for the project is to be sought.”
The applicant provided a letter from the zoning attorney for Victorian Village stating that they were pursuing appropriate zoning and met with staff from the Village of Homer Glenn regarding the project. According to the applicant appropriate zoning in the municipality could take several months for completion. THE STATE AGENCY FINDS THE PROPOSED PROJECT MEETS THE REQUIREMENTS OF THE ZONING CRITERION (77 IAC 1110.1730 (c))
D. Criterion 1110.1730(d) - Variances to Computed Nursing Care Bed Need - Continuum of Care
The criterion states:
“A) The applicant must document that the project will provide a
continuum of care for a geriatric population which includes independent living and/or congregate housing (such as unlicensed
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apartments, high rises for the elderly, and retirement villages) and related health and social services. Such housing complex must be on the same site as the health facility component of the project. Such a proposal must be for the purposes of and serve only the residents of the housing complex and may be developed in one of the following ways:
i) The proposal may be developed after the housing complex has been established; or
ii) The proposal may be developed as a part of a total housing construction program, provided that, the entire complex is one inseparable project and that there is a documented demand for the housing and that the licensed beds will not be built first, but will be built concurrently with or after the residential units.
B) The applicant must also document the following: i) That the proposed number of beds are needed.
Documentation shall consist of a list of available patients/residents needing the proposed project. The proposed number of beds may not exceed one licensed long-term care bed for every five apartments or independent living units; and
ii) That its written policies of operation provide that if a resident of the retirement community is transferred to the long-term care unit, the resident will not lose his or her apartment unit or be transferred to another long-term care facility solely because of the resident's altered financial status or medical indigency.”
The applicants propose to establish a 50-bed LTC unit within the CCRC. The proposed number of beds (50 beds) does exceed one licensed long-term care bed for every five apartments or independent living units. The applicant has stated that currently there is a 54 unit independent living facility, a 60 unit assisted living unit and 65 townhouses for a total of 179 units. The State Agency also notes that the January 2009 update to the State Board’s Inventory of Long-Term Care Services and Need Determination (“Inventory”) for the Will County LTC planning area shows a need for 311 LTC beds. The applicant’s proposed number of beds does not exceed the computed need for additional beds in the planning area.
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THE STATE AGENCY FINDS THE PROPOSED PROJECT MEETS THE REQUIREMENTS OF THE VARIANCE TO COMPUTED NURSING CARE BED NEED CRITERION 77 IAC 1110.1730 (d))
E. Criterion 1110.1730(e) - Staffing
“Applicants must document that the supply of manpower currently available in the area is sufficient to meet the health service needs in that area. Documentation should include, but is not limited to, letters from employment services in the area indicating the number of potential health care employees on their rolls; letters from local health departments, in whose jurisdiction the applicant is located, indicating the availability of personnel in the planning area; actual applications for employment on file with the applicant; and surveys performed by persons other than the applicant regarding the availability of manpower.” The applicants indicated that they currently operate and staff several skilled, assisted living and independent living retirement communities and therefore they employ staff at this site and at nearby areas. They provided a staffing plan of 33.9 FTEs needed for the proposed project. They stated they have applications on file that exceed the number of available positions. THE STATE AGENCY FINDS THE PROPOSED PROJECT MEETS THE REQUIREMENTS OF THE STAFFING CRITERION (77 IAC 1110.1730 (e))
IX. General Review Criteria
A. Criterion 1110.230(a) - Location The criterion states:
“An applicants who proposes to establish a new health care facility or a new category of service or who proposes to acquire major medical equipment that is not located in a health care facility and that is not being acquired by or on behalf of a health care facility must document the following:
1) that the primary purpose of the proposed project will be to provide care to the residents of the planning area in which the proposed project will be physically located. Documentation for existing facilities shall include patient origin information for all admissions for the last 12 months. Patient origin information must be presented by zip code and be based upon the patient's legal residence other than a health care facility for the last six
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State Agency Report Project #08-082 Page 14 of 25
months immediately prior to admission. For all other projects for which referrals are required to support the project, patient origin information for the referrals is required. Each referral letter must contain a certification by the health care worker physician that the representations contained therein are true and correct. A complete set of the referral letters with original notarized signatures must accompany the application for permit. 2) that the location selected for a proposed project will not create a
maldistribution of beds and services. Maldistribution is typified by such factors as: a ratio of beds to population (population will be based upon the most recent census data by zip code), within 30 minutes travel time under normal driving conditions of the proposed facility, which exceeds one and one half times the State average; an average utilization rate for the last 12 months for the facilities providing the proposed services within 30 minutes travel time under normal driving conditions of the proposed project which is below the Board's target occupancy rate; or the lack of a sufficient population concentration in an area to support the proposed project.”
As seen in Table One, there are 113 facilities with an occupancy rate below the State target occupancy rate of 90%. The applicant determined that the bed to population ratio within a 30-minute radius is 8,633 beds to 911,941 residents (based on 2008 census data), which results in 105.6 beds for each resident. The State Agency notes that the LTC facility is being built as part of a CCRC development and the purpose of the proposed LTC facility is to serve the residents of the CCRC. Therefore the facility will not impact the occupancy of area facilities, not create a maldistribution, and the primary purpose of the proposed project will be to provide care to the residents of the planning area in which the proposed project will be physically located. In addition the January 2009 update to the State Board’s Inventory of Long-Term Care Services and Need Determination (“Inventory”) for the Will County planning area shows a need for 311 LTC beds. THE STATE AGENCY FINDS THE PROPOSED PROJECT MEETS THE REQUIREMENTS OF THE LOCATION CRITERION (77 IAC 1110.230 (a))
B. Criterion 1110.230(b) - Background of Applicant
The criterion states: “The applicant shall demonstrate that it is fit, willing and able, and has the qualifications, background and character to adequately provide a proper standard
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of health care service for the community. [20 ILCS 3960/6] In evaluating the fitness of the applicant, the State Board shall consider whether adverse action has been taken against the applicant, or against any health care facility owned or operated by the applicant, directly or indirectly, within three years preceding the filing of the application.” The applicant is Rest Haven Illiana Christian Convalescent Home d/b/a Rest Haven Christian Services. The applicants certify they have not had any adverse actions taken by Medicare or Medicaid, or any State or Federal regulatory authority within the past three years. The applicant authorized the State Board and Agency access to information. The applicant owns and manages several other LTC facilities. The applicant facilities are licensed and Joint Commission Accredited. It appears the applicants are fit, willing and able and have the qualifications, background and character to adequately provide a proper standard of healthcare service for the community. THE STATE AGENCY FINDS THE PROPOSED PROJECT MEETS THE REQUIREMENTS OF THE BACKGROUND OF APPLICANT CRITERION 77 IAC 1110.230 (b))
C. Criterion 1110.230(c) - Alternatives to the Proposed Project
The criterion states: “The applicant must document that the proposed project is the most effective or least costly alternative. Documentation shall consist of a comparison of the proposed project to alternative options. Such a comparison must address issues of cost, patient access, quality, and financial benefits in both the short and long term. If the alternative selected is based solely or in part on improved quality of care, the applicant shall provide empirical evidence including quantifiable outcome data that verifies improved quality of care. Alternatives must include, but are not limited to: purchase of equipment, leasing or utilization (by contract or agreement) of other facilities, development of freestanding settings for service and alternate settings within the facility.” The applicant considered the following alternatives in addition to the proposed project:
1. Do Nothing: The applicants rejected this alternative because the current CCRC has residents who do not have the full continuum of care
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and the alternative fails to address the needs of the CCRC residents for access to higher levels of care. The applicant estimates that the cost of this alternative is nothing.
2. Construct a 100 bed free-standing facility: This alternative was rejected because its costs exceed the cost of the proposed project and because a larger facility would not be practical for the site due to land availability and zoning constraints. The applicant estimates that the cost of this alternative is $16,790,000.
3. Establish the facility as a CCRC: This alternative was rejected because with the computed bed need for 311 additional beds the CCRC variance is inapplicable, and building a smaller, 40-bed facility is less cost efficient, and occupancy of the facility would take longer given it could only be populated from within the community. The applicant estimates that the cost of this alternative is similar to the proposed project in addition to higher operating costs, increased resident fees and increased entrance fees. 4. Convert a portion of the existing assisted living facility to a skilled nursing care facility: The applicant rejected this alternative because the assisted and independent living facilities are fully-occupied and architectural constraints exist which would significantly increase costs of the conversion in order to design the facilities for skilled care. The applicant estimates that the cost for this alternative is $4,000,000. The State Agency notes that the LTC facility is being built as part of a CCRC development and the purpose of the proposed LTC facility is to serve the residents of the CCRC. Therefore the facility will not impact the occupancy of area facilities, not create a maldistribution, and the primary purpose of the proposed project will be to provide care to the residents of the planning area in which the proposed project will be physically located. In addition the January 20, 2009 update to the State Board’s Inventory of Long-Term Care Services and Need Determination (“Inventory”) for the Will County planning area shows a need for 311 LTC beds. The applicants are proposing a 50-bed facility. THE STATE AGENCY FINDS THE PROPOSED PROJECT MEETS THE REQUIREMENTS OF THE ALTERNATIVES TO THE PROPOSED PROJECT CRITERION (77 IAC 1110.230 (c))
D. Criterion 1110.230(d) - Need for the Project
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The need for this project is based on a need assessment per part 1100. The January 2009 update to the State Board’s Inventory of Long-Term Care Services and Need Determination (“Inventory”) for the Will County planning area shows a need for 311 LTC beds. The applicants are proposing a 50-bed facility. THE STATE AGENCY FINDS THE PROPOSED PROJECT MEETS THE REQUIREMENTS OF NEED FOR THE PROJECT CRITERION (77 IAC 1110.230 (d))
E. Criterion 1110.230(e) - Size of the Project
The criterion states: “The applicant must document that the size of a proposed project is appropriate. 1) The proposed project cannot exceed the norms for project size
found in Appendix B of this Part unless the additional square footage beyond the norm can be justified by one of the following: A) the proposed project requires additional space due to the
scope of services provided; B) the proposed project involves an existing facility where the
facility design places impediments on the architectural design of the proposed project;
C) the proposed project involves the conversion of existing bed space and the excess square footage results from that conversion; or
D) the proposed project includes the addition of beds and the historical demand over the last five year period for private rooms has generated a need for conversion of multiple bed rooms to private usage.
2) When the State Board has established utilization targets for the beds or services proposed, the applicant must document that in the second year of operation the annual utilization of the beds or service will meet or exceed the target utilization. Documentation shall include, but not be limited to, historical utilization trends, population growth, expansion of professional staff or programs (demonstrated by signed contracts with additional physicians) and the provision of new procedures which would increase utilization.”
a. Size
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The applicants are proposing the establishment of a 50-bed LTC facility in 39,030 GSF, which is 780.6 GSF per bed. This is in excess of the State standard of 414 GSF per bed. The applicants exceed the standard by 366.6 GSF, or 88.5%. The applicant recognizes that the size exceeds the State standard and indicates that the proposed facility is in three separate inter-related buildings, and that they are building a “small house” concept which duplicates a home-like environment and therefore creates space/department/service redundancies. The applicant points out that the LTC facility includes non-clinical services, and recently approved LTC facilities have similar GSF allocations. The applicant also notes that the project includes non-skilled area development for assisted and independent living and basement space.
b. Utilization
The applicant indicates that they project an average census of 45 patients, and an occupancy rate of 90%, which meets the State standard of 90%. This projection is based on current CCRC resident volume and community relations with their own home health agency and Marionjoy Rehabilitation Hospital. In addition the January 2009 update to the State Board’s Inventory of Long-Term Care Services and Need Determination (“Inventory”) for the Will County planning area shows a need for 311 LTC beds. The applicant is proposing a 50-bed facility. THE STATE AGENCY FINDS THE PROPOSED PROJECT DOES NOT MEET THE REQUIREMENTS OF THE SIZE OF THE PROJECT CRITERION
IX. Review Criteria - Financial Feasibility
A. Criterion 1120.210(a) - Financial Viability
The applicant is Rest Haven Illiana Christian Convalescent Home d/b/a Rest Haven Christian Services.
TABLE FOUR
Rest Haven Christian Services Ratio Standard 2005 2006 2007 2011
Current Ratio >=1.5 2.18 2.49 1.37 4.25 Net Margin Percentage >=2.5% -3.86% -1.18% 2.59% 6.61%
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Percent Debt to Total Capitalization <=80% 72.86% 70.90% 68.95 76.18% Projected Debt Service Coverage >=1.50 1.10 1.33 2.07 1.85 Days Cash on Hand >=75 92 118 118 115 Cushion Ratio >=3 4.31 4.42 5.54 3.00
The applicant does not meet the current ratio for 2007 or the net margin percentage for 2005 and 2006. The applicant does not meet the projected debt service coverage for 2005 and 2006. The applicant does not meet the ratio standards, did not provide any reasoning for not meeting the standards, and did not attest that any entity would assume legal responsibility to meet the debt obligations should the applicants default. As a result, the applicants do not meet the requirements for the variance. THE STATE AGENCY FINDS THE PROPOSED PROEJCT DOES NOT MEET THE REQUIREMENTS OF THE FINANCIAL VIABILITY CRITERION (77 IAC 1120.210 (a))
B. Criterion 1120.210(b) - Availability of Funds
The criterion states: “The applicant must document that financial resources shall be available
and be equal to or exceed the estimated total project cost and any related cost.”
The applicants are funding this project with cash and securities in the
amount of $2,139,508 and a mortgage in the amount of $8,558,031. The applicant provided documentation indicating that the company’s 2007 balance sheet shows available cash in the amount of $8,712,623 and investments in the amount of $16,835,587.
THE STATE AGENCY FINDS THE PROPOSED PROJECT MEETS THE REQUIREMENTS OF THE AVAILABILITY OF FUNDS CRITERION (77 IAC 1120.210 (b))
C. Criterion 1120.210(c) - Start-Up Costs
The criterion states: “The applicants must document that financial resources shall be available and be equal to or exceed any start-up expenses and any initial operating deficit.”
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The applicants indicate that they will incur start-up funds in the amount of $340,200. The applicant provided documentation indicating that the company’s 2007 balance sheet shows available cash in the amount of $8,712,623 and investments in the amount of $16,835,587. The applicant has sufficient resources available to meet the start-up costs and operating deficit.
THE STATE AGENCY FINDS THE PROPOSED PROJECT MEETS THE REQUIREMENTS OF THE START-UP COSTS CRITERION (77 IAC 1120.210 (c))
X. Review Criteria - Economic Feasibility
A. Criterion 1120.310(a) - Reasonableness of Financing Arrangements The criterion states:
“This criterion is not applicable if the applicant has documented a bond rating of "A" or better pursuant to Section 1120.210. An applicant that has not documented a bond rating of "A" or better must document that the project and related costs will be: 1) funded in total with cash and equivalents including investment
securities, unrestricted funds, and funded depreciation as currently defined by the Medicare regulations (42 USC 1395); or
2) funded in total or in part by borrowing because: A) a portion or all of the cash and equivalents must be retained
in the balance sheet asset accounts in order that the current ratio does not fall below 2.0 times;
B) or borrowing is less costly than the liquidation of existing investments and the existing investments being retained may be converted to cash or used to retire debt within a 60 day period. The applicant must submit a notarized statement signed by two authorized representatives of the applicant entity (in the case of a corporation, one must be a member of the board of directors) that attests to compliance with this requirement.
C) The project is classified as a Class B project. The co-applicants do not have a bond rating of “A”. No capital costs, except fair market value of leased space and used equipment, are being incurred by the co-applicants.
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The applicant is funding this project with cash and securities in the amount of $2,139,508 and a mortgage in the amount of $8,558,031. The applicant certify that a portion or all of the cash and equivalents will be retained in the balance sheet asset accounts in order that the current ratio does not fall below 2.0 times; or borrowing is less costly than the liquidation of existing investments and the existing investments being retained may be converted to cash or used to retire debt within a 60 day period.
THE STATE AGENCY FINDS THE PROPOSSED PROJECT MEETS THE REQUIREMENTS FOR THE REASONABLENESS OF FINANCING ARRANGEMENTS CRITERION (77 IAC 1120.310 (a))
B. Criterion 1120.310(b) - Terms of Debt Financing
This criterion states: “The applicant must certify that the selected form of debt financing the project will be at the lowest net cost available or if a more costly form of financing is selected, that form is more advantageous due to such terms as prepayment privileges, no required mortgage, access to additional indebtedness, term (years), financing costs, and other factors. In addition, if all or part of the project involves the leasing of equipment or facilities, the applicant must certify that the expenses incurred with leasing a facility and/or equipment are less costly than constructing a new facility or purchasing new equipment. Certification of compliance with the requirements of this criterion must be in the form of a notarized statement signed by two authorized representative (in the case of a corporation, one must be a member of the board of directors) of the applicant entity.” The applicant certifies that the selected form of debt financing the project is the lowest net cost available.
THE STATE AGENCY FINDS THE PROPOPSED PROJECT MEETS THE REQUIREMENTS OF THE TERMS OF DEBT FINANCING CRITERION (77 IAC 1120.310 (b))
C. Criterion 1120.310(c) - Reasonableness of Project Cost
The criteria states: “1) Construction and Modernization Costs
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Construction and modernization costs per square foot for non-hospital based ambulatory surgical treatment centers and for facilities for the developmentally disabled, and for chronic renal dialysis treatment centers projects shall not exceed the standards detailed in Appendix A of this Part unless the applicant documents construction constraints or other design complexities and provides evidence that the costs are similar or consistent with other projects that have similar constraints or complexities. For all other projects, construction and modernization costs per square foot shall not exceed the adjusted (for inflation, location, economies of scale and mix of service) third quartile as provided for in the Means Building Construction Cost Data publication unless the applicant documents construction constraints or other design complexities and provides evidence that the costs are similar or consistent with other projects that have similar constraints or complexities.
2) Contingencies
Contingencies (stated as a percentage of construction costs for the stage of architectural development) shall not exceed the standards detailed in Appendix A of this Part unless the applicant documents construction constraints or other design complexities and provides evidence that the costs are similar or consistent with other projects that have similar constraints or complexities. Contingencies shall be for construction or modernization only and shall be included in the cost per square foot calculation. BOARD NOTE: If, subsequent to permit issuance, contingencies are proposed to be used for other line item costs, an alteration to the permit (as detailed in 77 Ill. Adm. Code 1130.750) must be approved by the State Board prior to such use.
3) Architectural Fees
Architectural fees shall not exceed the fee schedule standards detailed in Appendix A of this Part unless the applicant documents construction constraints or other design complexities and provides evidence that the costs are similar or consistent with other projects that have similar constraints or complexities.
4) Major Medical and Movable Equipment
A) For each piece of major medical equipment, the applicant must certify that the lowest net cost available has been selected, or if not selected, that the choice of higher cost equipment is justified due to such factors as, but not limited
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to, maintenance agreements, options to purchase, or greater diagnostic or therapeutic capabilities.
B) Total movable equipment costs shall not exceed the standards for equipment as detailed in Appendix A of this Part unless the applicant documents construction constraints or other design complexities and provides evidence that the costs are similar or consistent with other projects that have similar constraints or complexities.
5) Other Project and Related Costs
The applicant must document that any preplanning, acquisition, site survey and preparation costs, net interest expense and other estimated costs do not exceed industry norms based upon a comparison with similar projects that have been reviewed.”
See page 200 of the application for permit for the itemization of costs listed below. Preplanning Costs – These costs are $44,000, or .59% of construction, contingencies, and equipment costs. This appears reasonable when compared to the State standard of 1.8%. Site Survey, Soil Investigation and Site Preparation – This cost is $326,000 or 4.60% of construction and contingency costs. This does not appear reasonable when compared to the State Agency Standard of 5%.
Off-Site Work – These costs total $40,000. The State Board does not have a standard for this cost. New Construction and Contingencies – These cost is $7,080,529 or $181.41 per GSF. This appears reasonable when compared to the State Agency standard of $200.51 per GSF. Contingencies - This cost is $599,496 and represents 9.25% of new construction costs and appears reasonable when compared to the State Agency standard of 10%. Architectural and Engineering Fees - This cost is $397,500 or 5.6% of construction and contingencies. This appears reasonable compared to the State standard of 4.10% - 8.85%.
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Consulting and Other Fees – This cost is $422,422. The State Agency does not have a standard for this cost.
Moveable Equipment - These costs total $375,365 or $7,507/bed. This appears high when compared to the State standard of $7,114/bed. ($6,510/bed inflated by 3% to the year 2011) Loan Origination Fee – these costs are $227,216. The State Agency does not have a standard for this cost. Net Interest During Construction – This cost is $477,152. The State Agency does not have a standard for these costs. Other costs to be capitalized - This cost is $1,125,580. The State Agency does not have a standard for these costs. THE STATE AGENCY FINDS THE PROPOSED PROJECT MEETS THE REQUIREMENTS OF THE REASONABLENESS OF PROJECT COST CRITERION (77 IAC 1120.310 (c))
D. Criterion 1120.310(d) - Projected Operating Costs
The criterion states: “The applicant must provide the projected direct annual operating costs (in current dollars per equivalent patient day or unit of service) for the first full fiscal year after project completion or the first full fiscal year when the project achieves or exceeds target utilization pursuant to 77 Ill. Adm. Code 1100, whichever is later. Direct costs means the fully allocated costs of salaries, benefits, and supplies for the service.”
The applicants project $261 of annual operating costs per equivalent patient day for the first year of operation or when the facility meets target occupancy. The State Board does not have a standard for this cost. Since the applicants provided the required information, the State Agency can make a positive finding. THE STATE AGENCY FINDS THE PROPOSED PROECT MEETS THE REQUIREMENTS OF THE PROJECTED OPERATING COSTS CRITERION (77 IAC 1120.310 (d))
E. Criterion 1120.310(e) - Total Effect of the Project on Capital Costs
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The criterion states: “The applicant must provide the total projected annual capital costs (in current dollars per equivalent patient day) for the first full year after project completion or the first full fiscal year when the project achieves or exceeds target utilization pursuant to 77 Ill. Adm. Code 1100, whichever is later.” The applicants project $57 per adjusted patient day in annual capital costs for the first year of operation. The State Board does not have a standard for this cost. Since the applicants provided the required information, the State Agency can make a positive finding. THE STATE AGENCY FINDS THE PROPOSED PROJECT MEETS THE REQUIREMENTS OF THE TOTAL EFFECT OF THE PROJECT ON CAPITAL COSTS CRITERION (77 IAC 1120.310 (e))
F. Criterion 1120.310(f) - Non-Patient Related Services
This criterion is not applicable.
THE STATE AGENCY NOTES THE NON-PATIENT RELATED SERVICES CRITERION IS NOT APPLICABLE TO THIS PROJECT.