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COMPLETENESS REVIEW QUESTIONSNAME OF FACILITY

: Christ Hospital

CERTIFICATE OF NEED NUMBER

: CN# FR 111101-09-01

NAME OF REVIEWER:

Anthony Kobylarz / Jeff Kasko

TELEPHONE NUMBER OF REVIEWER:

(609) 292-65521.Your projections on page 11 of 19 indicate admissions for medical/surgical,pediatrics, acute psychiatric, obstetrics, the intensive care unit and newbornnursery would not change in 2012 and 2013 from the reported admissions in 2011.Explain how in light of the fact that admissions have declined for a number of theseservices for the last two years and without any additional growth that the newownership would successfully stabilize the hospital’s operation.2.The application indicates that you are committed to operating Christ Hospital for the next five years. Do you propose to continue operating the same number of licensed as well as maintained beds during this time period? If not, provide your explanation for any reductions or increases in the respective bed categoriescurrently identified on the hospital’s license, which you plan to implement.3.Under the Maintenance of Services section on page 4 of the

Proposal to Purchase Assets of Christ Hospital

letter, you do not identify pediatric beds as an essentialservice to be offered for no less than five years. Explain whether you arecommitted to providing these services at the present bed level once the ownershipof the hospital is transferred to Prime Healthcare.4.On page 9 of 19 of the application, you indicate that Christ Hospital has beendesignated by the New Jersey Department of Health and Senior Services as acritical access/safety net hospital. Please provide a copy of the documentationreceived from the Department.5.As requested in Schedule B, please submit the track record reports for all of thelisted facilities owned by Prime Healthcare for the preceding 12 months. Theseshould come from the California state agencies responsible for licensing thosefacilities and indicate the degree of compliance with all state and federalrequirements.6.You reference on page 6 that your plans to work collaboratively with other areahospitals (Jersey City Medical Center and Hoboken University Medical Center) toexplore long-term patient service consolidation opportunities. Identify the potentialservice opportunities that you are considering, status of any discussions with other area hospitals, and how you determined the consolidation of these services wouldbest serve the area.

Christ Hospital Completeness QuestionsPage 2

7.What measures does Prime Healthcare intend to implement to enhance ChristHospital’s ability to recruit and sustain the appropriate complement of physicians,clinical staff and support personnel, thus ensuring the long-term viability of thehospital? Explain your response in detail.8.You state that Prime Healthcare has committed to hire substantially all of ChristHospital’s employees. Please provide the date to which this statement applies.Please also identify the current total number of employees and what number wouldbe maintained by the new owners. In addition;a.What efforts will Prime Healthcare undertake to assist employees who willnot be maintained to find other suitable employment?b.Would the transfer of ownership result in any changes in the currentcontracts with any professional staff? If so, please explain.9.You indicate that Medicaid and uninsured patients made up 40% of ChristHospital’s payer mix in 2010 – an increase of 17% over the prior two years. Withthis population’s continued growth or even its stabilization over the next two years,how do you propose to dedicate hospital resources to treat these patients withoutincreasing your financial deficit?10.What do you see as the payer mix for Christ Hospital for 2012 and 2013? Reportthese figures in terms of number of patients and percentage of the total patientpopulation you project for each of these two years.11.You indicate that Prime Healthcare operates 12 for-profit acute care hospitals andtwo non-profit hospitals under its affiliated Prime Healthcare Services Foundationin California. For each of those hospitals, individually provide the number andpercentage of patients that were admitted through the Emergency Department(ED) over the past two years. Of these patients admitted through the ED, indicatethe number and percentage that were out-of-network in terms of insurance status.For both of these items, indicate how they compare to the California average.12.For these same 14 hospitals, please report the payer mix for each over the pasttwo years, by number and percentage of patients, including charity care, or asimilar program, and Medicaid patients. Please also indicate how the percentagesfor each hospital’s payer category compare with the averages for all Californiahospitals.13.According to a published report on 2008 to 2010 diagnosis rates byCaliforniaWatch.com (CW), Prime Healthcare hospitals in California had asignificantly higher percentage of Medicare patients diagnosed with acute heartfailure than other California hospitals. During this time, Prime Healthcare hospitalshad 12.9% of Medicare patients with this diagnosis, compared to 4.8% of thesepatients in other hospitals. CW data also show that Prime Healthcare hospitalswere in the top three, percentage-wise, and were included in five of the top six, and

Christ Hospital Completeness QuestionsPage 3

eight of the top ten (with ranges of 12.3% to 35.2%) of hospitals diagnosing acuteheart failure during these years. Please explain this in more detail.14.What rationale did you receive from the Office of the California Attorney Generalor California Department of Health in the denial of a number of Prime Healthcareproposals to convert non-profit to for-profit hospitals? Provide the documentationfrom these government agencies that spells out this rationale.15.The

Proposal to Purchase Assets of Christ Hospital

letter specifies that thecontinued operation of Christ Hospital would be not less than five years. How didyou determine the length of operational time before selling or discontinuingservices to be five years instead of a seven or ten year time period? Is PrimeHealthcare prepared to commit to operating Christ Hospital for more than fiveyears after initial licensure, if required by certificate of need approval to do so? If not, please explain why? Has Prime Healthcare sold any of the hospitals that theyconverted from non-profit to for-profit within seven years or less from their statelicensure date? If so, please explain the reasons for the sale and whether thefacilities continued to operate as hospitals.16.Explain how Prime Healthcare will build upon Christ Hospital’s existingcommitment to the medically indigent as stated on page 14 of Section B.17.On Page 9 of Section II of the application, you mention specific deficiencies for Christ Hospital to address in order to continue to provide crucial care to HudsonCounty residents. Outline your plan to address these deficiencies.18.Does Prime Healthcare plan to acquire the existing Medicare Provider Number of Christ Hospital or obtain a new one?a.If keeping the existing Medicare provider number, please describe anyliabilities pertaining to the Medicare provider number being acquired and howthese are accounted for in the financial data presented.b.

If acquiring a new Medicare provider number, please describehow the facility will comply with CMS conditions of participation as anew provider, especially required Federal Life Safety Coderequirements (most recent code requirements).

19.On page 19 of Section B of the application, you address the criteria of N.J.A.C.8:33-4.9. The statements provided lack the required specificity needed todemonstrate compliance. In accordance with general criteria for Certificate of Need (CN) approval at N.J.S.A. 26:2H-8 and N.J.A.C. 8:33-4.9(a), please providedetailed responses to the criteria set forth below:a.the availability of facilities or services which may serve as alternatives or substitutes;