Interfaith Hospital is the Brooklyns largest private provider of in-patient psychiatric care.

Right now, it is in bankruptcy, and teetering at the brink of closure. According to filings with the Federal bankruptcy court, Interfaith will close its Emergency Room on September 14th, and end inpatient programs on September 15th.1 A closure of Interfaith would be a grievous blow to psychiatric care in Brooklyn. It would place Brooklyns psychiatric safety net dangerously overcapacity. It would deny access to psychiatric and quality mental health care based entirely on where a person lives, not the type of care they need. This is a City responsibility. Mayor Bloombergs silence on hospital closures is untenable. Losing Interfaith would have a devastating impact on psychiatric care in Brooklyn and Queens, and threatens to overwhelm City psychiatric services at public hospitals already burdened by crowding. The State has a moral and legal obligation to consider and minimize the dire consequences of a closure that does not retain net psychiatric capacity and ensure that people seeking psychiatric care in Brooklyn are not left on their own.2 Interfaith Serves a Population In Particular Need of Psychiatric Care The people who live in the area surrounding Interfaith and who use it as their community hospital (the catchment area) are particularly in need of psychiatric services, compared to those in other boroughs, or even other Brooklyn neighborhoods. Brooklyn residents are more likely to use inpatient psychiatric services than the statewide average, 5.8 per 10,000 versus 5.0 per 10,000.3 At Interfaith in particular, those admitted to the hospital for injuries or physical illness are often also suffering from psychiatric health issues requiring special care or admission to inpatient psychiatric services. Sixty percent (60%) of all patients discharged from Interfaith hospital have a psychiatric condition as either the principal diagnosis, or as a comorbidity, compared to 27% across Brooklyn.4 Interfaith is the Largest Voluntary Provider of Inpatient Psychiatric Care in Brooklyn This closure would have serious consequences for the provision of psychiatric care in Brooklyn. Interfaith is the
Nina Bernstein, Interfaith Medical Center Plans to Close, NY Times, July 31, 2013. New York State Department of Health Regulation 709.1(6), outlining that a determination of a public need in the case of the reduction or elimination of a service should be guided by the extent to which need will be met adequately and the effect of the reduction, elimination, or relocation of the service or facility on the ability of the low-income persons, racial and ethnic minorities, women, handicapped person, and other underserved groups, and the elderly, to obtain needed health care. See also, NY Public Health Law 2801-g, requiring the Commissioner to consider and receive public input on the anticipated impact of the general hospital's closure on access to health care serv ices by members of the surrounding community, including but not limited to recipients of medical assistance for needy persons, the uninsured, and underserved populations, and options and proposals to ameliorate such anticipated impact. 3 Medicaid Redesign Team Brooklyn Health Systems Redesign Working Group, At th e Brink of Transformation: Restructuring the Healthcare Delivery System in Brooklyn, November 2011. Available at http://www.health.ny.gov/health_care/medicaid/redesign/docs/brooklyn_mrt_final_report.pdf. 4 Ibid.
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largest private provider (and third overall largest provider) of inpatient psychiatric care in Brooklyn, with more than 1750 annual psychiatric discharges, and 120 inpatient beds devoted to psychiatric care. 5 These beds account for 13.5% of the total inpatient psychiatric capacity in the borough.6 The hospital also handles approximately 67,000 outpatient psychiatric patients each year. 7 Two public hospitals operated by the City of New Yorks Health and Hospital Corporation, Kings County Hospital Center and Woodhull Medical & Mental Health Center, have 452 and 435 beds, respectively. These hospitals are full: on an average day they operate at 96% (Kings County) and 94% (Woodhull) capacity. Losing Interfaiths Psychiatric Capacity Would Overburden Surrounding Hospitals. 91% Capacity on an Average Day Would Rise to 107% Overcapacity. Without the services available at Interfaith, Brooklyns psychiatric in-patient capabilities would go from strained to dangerously over-capacity. An analysis of 2011 data by the Public Advocates Office shows that, on an average day, Brooklyn inpatient psychiatric beds are 91% full. If Interfaith were to close, a thin surplus of beds would turn into a deficit with the total number of inpatients seeking care on an average day equal to 107% the number of available inpatient beds available.8 On an average day, 714 people are receiving inpatient psychiatric care in Brooklyn hospitals, a total of 10,141 psychiatric discharges each year. In 2011, Brooklyn had 889 inpatient psychiatric beds with approximately 810 people receiving inpatient psychiatric care at any given day, an occupancy rate of approximately 91.2%. In the past year, Brooklyn has already lost over 100 psychiatric inpatient beds at Coney Island Hospital, as a result of damage from Superstorm Sandy, and at Long Island College Hospital (LICH), as a result of contentious closure of that institution by the State University of New York. A loss of Interfaiths additional 120 inpatient psychiatric beds, which are currently operating at 95.7% occupancy, would mean the number of people needing inpatient psychiatric care in Brooklyn would be equal to 107% the available 2011 capacity, and 122% the available capacity assuming the patients who were once psychiatric inpatients at LICH and Coney Island are currently seeking care in Brooklyn as well. Two other struggling Brooklyn hospitals Brookdale Hospital Medical Center and Kingsbrook Jewish Medical Center, for an additional 100 inpatient psychiatric beds. Based on the average daily occupancy of these psychiatric facilities, the loss of these hospitals (in addition to Interfaith, Coney Island, and LICH) would yield an overcapacity of approximately 143% -- a staggering mismatch between people in need of serious psychiatric care, currently offered by inpatient services, and the capacity to help them. Other Private Hospitals Rely on Interfaiths Psychiatric Services to Provide Care to Their Patients Other providers in Brooklyn without their own psychiatric capacity rely on Interfaith provide care to their patients. For example, in 2012, Interfaith reached an agreement with Wyckoff Heights Medical Center to be the sole provider
Psychiatric inpatient discharges, a measure of the volume of inpatient services provided by a facility, was 1773 in 2011, the most recent data available from the New York State Office of Mental Health. Available at http://bi.omh.ny.gov/cmhp/dashboard#tab5 . 6 Based on 2011 data from the New York State Department of Health. Bed capacity for Coney Island Hospital, which closed due to damage related to Superstorm Sandy. It also does not include inpatient psychiatric capacity once available at Long Island College Hospital (LICH). 7 Nina Bernstein, Brooklyn Hospital Closings a Blow to Psychiatric Care, NY Times August 1, 2013.
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8 2011Medicare Cost Reports.

of behavioral health services, including inpatient, outpatient, and emergency psychiatric care, evaluations of patients with substance abuse problems, and other mental health services.9 Ramon Rodriguez, CEO of Wyckoff Heights Medical Center recently said that, "When Interfaith closes, we will have no place where we can send a decompensating mentally ill person from our emergency departmentInterfaith is the only provider of inpatient behavioral health that accepted our patients."10 A Free-Fall Closure Is No Solution Even if an eventual transformation of Brooklyn mental health would include a reduction in inpatient psychiatric beds, a free-fall post-bankruptcy closure is no way to do it. A shuttering of Interfaith would not be a smooth and coordinated process envisioned by the 2011 Brooklyn Medicaid Redesign Team. That document identified a need to adequately support the effective management of behavioral health conditions in the community by reducing the need for inpatient care, integrating medical and beha vioral care, coordinating along a continuum of care, improve early intervention, and investments in supportive housing housing, employment and education. 11 The current bankruptcy and shuttering would not accomplish that -- it would eliminate capacity without replacing it with alternative options, leaving those seeking psychiatric care to go to another, already crowded, Brooklyn inpatient facility, or worse, go without any care at all. The Public Advocate is recommending the following course of action to rescue and reform the provision of psychiatric care at Interfaith and across Brooklyn:

The City, State, and Interfaith leadership need to step up to avert a free fall closure and think creatively on
solutions that can retain psychiatric capacity and ensure quality psychiatric care adequate to address Brooklyns challenges.

We need a Brooklyn Health Authority, empowered through control of Federal Medicaid Waiver finds to guide a
master plan for the equitable reorganization and reform of Brooklyn hospitals and health care. Among their recommendations, the Brooklyn Health Authority should encourage existing hospitals with excess beds to

Wyckoff Heights Medical Center, INTERFAITH MEDICAL CENTER TO PROVIDE WYCKOFF HEIGHTS MEDICAL CENTER BEHAVIORAL HEALTH SERVICES, Press Release October 1, 2012. Available at http://www.wyckoffhospital.org/about/news-events/interfaith-wyckoffbehavioral-health-services-collaboration. 10 Fred Mogul, WNYC, Kaiser Health News, Cascading Hospital Closures Loom Over Brooklyn, August 5, 2013, available at http://www.kaiserhealthnews.org/stories/2013/august/05/brooklyn-new-york-hospital-closings-loom.aspx 11 Medicaid Redesign Team Brooklyn Health Systems Redesign Working Group, At the Brink of Transformation: Restructuring the Healthca re Delivery System in Brooklyn, November 2011. Available at http://www.health.ny.gov/health_care/medicaid/redesign/docs/brooklyn_mrt_final_report.pdf.
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transform some of their beds into inpatient psychiatric beds in order to meet the growing demand for psychiatric care across Brooklyn.

Interfaith is currently operating under a Federal requirement, known as the Institute for Medical Disease (IMD)

Exclusion that prevents them from receiving Medicaid matching funds if more than 51% of their patient roster consists of people between the ages of 22 and 64 with severe mental illness. The Federal government should change these rules to exempt those patients covered by a Medicaid Managed Care plan for counting towards a hospitals 51% limit under the IMD exclusion. This common sense change would allow Interfaith to accept more psychiatric patients, shoring up their balance sheets and stabilizing the hospitals, without increasing the costs to the Federal government (as their payments to the Medicaid Managed Care provider would remain the same). integrate better into existing health networks, by accepting referrals from voluntary hospitals, and stepping in to provide services when voluntary hospitals are insufficient or unable to meet community care needs.

Finally, we need to explore ways for the Citys Health and Hospitals Corporation to increase their ability to