STATE AGENCY ACTION REPORT ON APPLICATION FOR CERTIFICATE OF NEED - Florida

Transcription

STATE AGENCY ACTION REPORTON APPLICATION FOR CERTIFICATE OF NEEDA.PROJECT IDENTIFICATION1.Applicant/CON Action NumberIndian River Behavioral Health, LLC/CON #10233999 Ponce de Leon Boulevard, Suite 950Coral Gables, Florida 33134Authorized Representative:2.Roz HudsonDivisional Vice President(305) 444-5007Service DistrictDistrict 7 (Brevard, Orange, Osceola, and Seminole Counties)B.PUBLIC HEARINGA public hearing was not held or requested on the proposed project toestablish a new Class III Specialty Hospital with 74 child and adolescentinpatient psychiatric beds in Brevard County, Florida.Letters of SupportThe applicant submitted 23 unduplicated letters of support.Dr. Kathy D. Pearce, PhD, psychologist at Brevard Psychology & LearningCenter, states she has seen first-hand that the need for a child andadolescent behavioral hospital in Brevard County has becomeincreasingly urgent over the past decade. Maria Bledsoe, Chief ExecutiveOfficer (CEO) of the Central Florida Cares Health System Inc., indicatesthat as a leader of a company that manages substance abuse and mentalhealth, “As the Managing Entity for Circuits 9 and 18, I can attest to theneed for children and adolescent behavioral health services in BrevardCounty.”Andy Anderson, Brevard County Commissioner for District 5, states that“It is my understanding that the Brevard County Community HealthImprovement Plan from 2013-2016 recommended that Brevard County

CON Action Number: 10233improve our behavioral health services so that children are active, selfsufficient participants in our community. I could not agree more and seea need for additional child and adolescent psychiatric beds in ourcounty. I am excited about this project.”Dr. A. Amir Mirsajadi, M.D., Board Certified Psychiatrist, and James V.Eaten, President and Clinical Director, colleagues at Adult & ChildCounseling Center & Psychiatric Center, voice their support for theproposed project. Dr. Mirasjadi states, “I believe having a hospital inBrevard would optimize the ability for families to be more involved infamily therapy sessions, visitation and meetings with their loved onescare team.” Mr. Eaten writes, “Because we do not currently have thislevel of inpatient care available within our county, it is unfortunate, butthere are many residents in need of acute inpatient treatment who neverseek or access it.”Letter of OppositionThe Agency received two letters of opposition. Mr. James B. Whitaker,President and CEO of Circles of Care, Inc., submitted a letter signed anddated October 6, 2014. Mr. Whitaker writes that Brevard County iscurrently serviced by a freestanding 16-bed child and adolescentpsychiatric facility owned and operated by Circles of Care, Inc. Hebelieves there has not been the kind of population growth in BrevardCounty needed to sustain an additional child psychiatric hospital in thecommunity and notes Circles of Care reported an occupancy rate of 51percent in the fiscal year ending June 30, 2014. Mr. Whitaker feels theproposed project could quadruple the number of existing childpsychiatric beds in a community where 50 percent of the existing bedsremain empty. Mr. Whitaker mentions that the proposed project is a forprofit facility--whose care and treatment of such patients would be doneat a cost to the state.In addition, Mr. Whitaker states his concern about the availability ofpsychiatrists and qualified nursing staff in Brevard County. Lastly, Mr.Whitaker believes the proposed for-profit facility would be unable toprovide a scope of services as full as Circles of Care currently offers.Mr. Whitaker submitted a signed attachment, dated October 10, 2014, tohis original letter. He states that based on the historical behavior ofUniversal Health Services (UHS—the parent company of the applicant), ifthe CON is granted, Indian Rive Behavioral Health will delicense some orall of its child and adolescent psychiatric beds. Mr. Whitaker states thatopening a large children’s hospital will adversely affect the ability ofCircles to continue to serve the uninsured and the under-insured thatprivate for-profit facilities, such as the applicant, typically do not serve.2

CON Action Number: 10233The second letter of opposition was submitted on behalf of DevereuxFlorida by Mr. Steven J. Murphy, Executive Director, signed and datedOctober 8, 2014. Mr. Murphy asserts that Devereux has been partneringwith the Agency for 27 years and is part of a larger continuum of servicesthe Agency utilizes in Brevard County. Mr. Murphy believes Devereux isbetter positioned to ensure that seamless services are offered instead ofjust a new freestanding hospital.Furthermore, Mr. Murphy believes Devereux Florida can meet any unmetneed for child and adolescent care due to its plans to expand services bybecoming a Statewide Inpatient Psychiatric Program (SIPP). Mr. Murphynotes that Devereux recently met with the Agency to become a SIPPprovider in Brevard County. He states that Devereux is in the process ofcompleting its application and anticipates providing this service within afew weeks. Mr. Murphy states Devereux’s status as a non-profit entityensures that state funds are utilized with the patient and community asthe highest priority, not shareholders.Mr. Murphy states that Devereux partners with the community to meetneeds through various programs, including the newly developed programto serve Commercially Sexually Exploited Children (CSEC) that thelegislature recently appropriated funds for Devereux to implement.Mr. Murphy contends that should the proposed project be approved, itwould jeopardize the CSEC program by diverting patients whichultimately fund these community-based programs.In addition, Mr. Murphy indicates that approval of the proposed projectwould place an unmanageable level of competition for staff in BrevardCounty, increasing the cost to deliver care while also negativelyimpacting quality of care. Lastly, Mr. Murphy states UHS has a historyof approaching the Agency with a CON application for child andadolescent psychiatric beds, getting approval for these beds, and thenlater converting these beds to adult psychiatric. Mr. Murphy indicatesthis scenario has occurred with 60 of UHS’s beds in District 7 over thelast four years, 31 of which were converted to adult psychiatric beds onlyafter a year of being originally approved as child and adolescent.The reviewer confirms that 65 UHS District 7 beds were givenexemptions or notifications to convert from child and adolescentpsychiatric beds to adult psychiatric or substance abuse beds fromJuly 18, 2010 to July 18, 2014. The following is a list of the requestedand approved exemptions and notifications of District 7 UHS facilitiesthat converted beds:3

CON Action Number: 10233 C.E120012 for University Behavioral Center to establish a 28-bed adultinpatient psychiatric unit by delicensing 28 child and adolescentpsychiatric beds (approved October 23, 2012)—although the reviewernotes that four of these beds were obsoleted through NF140023E120016 for University Behavioral Center to establish a 12-bed adultinpatient substance abuse unit by delicensing 12 child andadolescent inpatient psychiatric beds (approved May 19, 2014)NF1100023 for Central Florida Behavioral Hospital to add three adultpsychiatric beds through the conversion of three child and adolescentpsychiatric beds (received July 28, 2011)NF 120023 for Central Florida Behavioral Hospital to add 14 adultpsychiatric beds through the conversion of 14 child and adolescentpsychiatric beds (received April 24, 2012)NF130009 for Central Florida Behavioral Hospital to add 17 adultinpatient psychiatric beds through the conversion of 17 child andadolescent inpatient psychiatric beds (received April 17, 2013)NF140023 for University Behavioral Center to add 12 adult inpatientpsychiatric beds through the delicensure of 12 child and adolescentinpatient psychiatric beds (received May 16, 2014)PROJECT SUMMARYIndian River Behavioral Health, LLC (CON application #10233), wasformed by and is a wholly owned subsidiary of the parent companyUniversal Health Services, Inc. (UHS) for the purpose of filing theproposed project and will be referred to as IRBH or the applicant. IRBHproposes to establish a new Class III Specialty Hospital with 74 child andadolescent inpatient psychiatric beds in District 7, Brevard County,Florida.The applicant states UHS’s Behavioral Health Division operates a total of193 behavioral health facilities worldwide, with 10 adult psychiatrichospitals in Florida, and an 11th and 12th hospital approved in Marionand Flagler Counties, respectively. Atlantic Shores HospitalCentral Florida Behavioral Hospital (CFBH)Emerald Coast Behavioral HospitalFort Lauderdale HospitalGulf Coast Treatment CenterRiver Point Behavioral HealthThe Vines HospitalUniversity Behavioral Center (UBC)Windmoor Healthcare of Clearwater4

CON Action Number: 10233 Wekiva Springs CenterTreasure Coast Behavioral Health (Approved)Palm Coast Behavioral Health (Approved)The reviewer notes that Gulf Coast Treatment Center is comprised solelyof 24 child and adolescent psychiatric beds, with no licensed adultpsychiatric beds.UHS also operates residential treatment facilities throughout Florida,including La Amistad Residential Treatment Center, which is anIntensive Residential Treatment Facility (IRTF) in District 7. In additionto La Amistad, four of the hospitals listed above also provide residentialtreatment for children and adolescents: CFBH, UBC, Emerald CoastBehavioral Hospital and Fort Lauderdale Hospital.The proposed project involves 50,361 gross square feet (GSF) of newconstruction. The construction cost is 9,044,535. Total project cost is 16,737,262. Project cost includes land, building, equipment, projectdevelopment, financing and start-up costs.The applicant proposes to condition the project as shown below: IRBH will be located in Brevard CountyIRBH will become a designated Baker Act Receiving Facility uponlicensure and certificationUpon licensure and certification, IRBH will seek Joint CommissionAccreditationThe applicant will provide at least 35 percent of its total hospitalpatient days to a combination of Medicaid HMO/charity care/self-paypayors by year two of operation and thereafterIRBH will seek to become a training site for Eastern Florida StateCollege and University of Central Florida (UCF), and any others in thearea, for nursing students, social services, activities therapy andothersIRBH will seek to become a residency training site for UCF College ofMedicineThe applicant will support local community based not-for-profitadvocacy groupsIRBH will support the National Alliance of Mental Illness (NAMI)’s localgrass roots efforts by assisting and expanding their presence inBrevard CountyThe applicant states that all of these conditions will be measured byfurnishing the Agency with certificates, utilization data and otherinformation as needed on an ongoing basis.5

CON Action Number: 10233NOTE: Section 408.043 (4) Florida Statutes, prohibits accreditation byany private organization as a requirement for the issuance ormaintenance of a certificate of need, so Joint Commission accreditation(condition #3) will not be cited as a condition to approval. Should theproject be approved, the applicant’s proposed conditions would bereported in the annual condition compliance report as required by Rule59C-1.013 (3) Florida Administrative Code.D.REVIEW PROCEDUREThe evaluation process is structured by the certificate of need reviewcriteria found in Section 408.035, Florida Statutes; and applicable rulesof the State of Florida, Chapters 59C-1 and 59C-2, FloridaAdministrative Code. These criteria form the basis for the goals of thereview process. The goals represent desirable outcomes to be attained bysuccessful applicants who demonstrate an overall compliance with thecriteria. Analysis of an applicant's capability to undertake the proposedproject successfully is conducted by evaluating the responses and dataprovided in the application, and independent information gathered by thereviewer.Applications are analyzed to identify strengths and weaknesses in eachproposal. If more than one application is submitted for the same type ofproject in the same district, applications are comparatively reviewed todetermine which applicant(s) best meets the review criteria.Rule 59C-1.010(3)(b), Florida Administrative Code, prohibits anyamendments once an application has been deemed complete. Theburden of proof to entitlement of a certificate rests with the applicant.As such, the applicant is responsible for the representations in theapplication. This is attested to as part of the application in theCertification of the Applicant.As part of the fact-finding, the consultant, Lucy Villafrate analyzed theapplication with consultation from the financial analyst, EverettBroussard, of the Bureau of Central Services, who evaluated the financialdata and Said Baniahmad of the Office of Plans and Construction, whoreviewed the application for conformance with the architectural criteria.6

CON Action Number: 10233E.CONFORMITY OF PROJECT WITH REVIEW CRITERIAThe following indicate the level of conformity of the proposed project withthe criteria and application content requirements found in FloridaStatutes, sections 408.035 and 408.037; applicable rules of the State ofFlorida, Chapter 59C-1 and 59C-2, Florida Administrative Code.1.Fixed Need Poola.Does the project proposed respond to need as published by a fixedneed pool? Or does the project proposed seek beds or services inexcess of the fixed need pool? Rule 59C-1.008 (2), FloridaAdministrative Code.In Volume 40, Number 39 of the Florida Administrative Register datedJuly 18, 2014, a fixed need pool of 74 beds was published for child andadolescent inpatient psychiatric beds in District 7 for the July 2020Planning Horizon. The applicant’s project is in response to the publishedneed.As of July 18, 2014, District 7 had 275 licensed and negative 30approved child and adolescent inpatient psychiatric beds. During the12-month period ending December 31, 2013, District 7’s child andadolescent beds experienced 78.26 percent utilization at five existingfacilities.Of the five facilities in District 7 with licensed child and adolescentinpatient psychiatric beds, one is a Class 1 hospital (South SeminoleHospital), three are Class 3 hospitals (Devereux Florida, CFBH and UBC)and one is a Class 4 hospital (La Amistad).The applicant proposes to locate its facility in Brevard County, whichfalls in District 7 along with Orange, Osceola, and Seminole Counties.The applicant indicates that while these other three counties are referredto as “central Florida,” Brevard County is perceived as a separate market,commonly referred to as the “Space Coast.” IRBH describes the countyas a bedroom community to the Orlando metropolitan area, but also ashaving a distinct medical market with two predominant health systems,Health First and Wuesthoff Health System.IRBH maintains that the Agency’s count of 275 licensed and 10 approvedchild and adolescent beds1 for District 7 is misleading because IRTF bedsare included in the need formula even though IRTFs and hospitals offerThe reviewer notes the applicant is not considering notifications and exemptions submitted to theAgency to delicense child and adolescent psychiatric beds in this statement, but does acknowledgethem in a subsequent chart, then finding the number of approved beds to be -30.17

CON Action Number: 10233different levels of care. The applicant states that IRTFs do not provideacute crisis stabilization nor short-term treatments, therefore they onlyfocus on providing the long-term residential component. IRBH declaresonly 135 of the 275 beds are actually hospital providers that can provideacute crisis stabilization. Furthermore, due to current notifications,exemptions, and CONs filed with the Agency, the existing 275 bed counttoday will be reduced to 245 beds dedicated to children and adolescents.IRBH notes all 100 child and adolescent beds located in Brevard Countyare IRTF beds at Devereux Florida. The applicant asserts that Devereuxcannot become a Baker Act Receiving Facility and does not provide acutestabilization or short-term treatment. The reviewer confirms on theAgency’s FloridaHealthFinder.gov website that Devereux is not a BakerAct Receiving Facility as of October 29, 2014.Additionally, IRBH insists that even if Devereux did provide similarservices as the proposed applicant, Devereux has already achieved astabilized occupancy rate of 75 percent, given isolation and diagnosesissues. According to the applicant, genders cannot be comingled inpatient rooms or connecting rooms, further decreasing bed availability.The reviewer confirms that Devereux’s occupancy rate for January 2013through December 2013 was 75.03 percent according to the FloridaHospital Bed Need Projections & Service Utilization by District—July 2014Batching Cycle published July 18, 2014.The applicant contends that Devereux focuses much of its efforts onattracting nonlocal patients. IRBH indicates that during Calendar Year(CY) 2013, less than two percent of Devereux’s patient days were BrevardCounty residents and two percent were residents from the remainder ofDistrict 7. The applicant maintains that Devereux provided 73.7 percentof its days to out-of-state residents. Please see the chart below.Devereux Utilization by Patient Origination CY 2013Patient OriginationBrevard CountyDistrict 7 TotalFlorida TotalOutside FloridaTotalCases49315990Patient Days6021,2568,24023,05731,297Percent ofTotal Cases4.4%10.0%34.4%65.6%100.0%Percent ofTotal Days1.9%4.0%26.3%73.7%100.0%Source: CON application #10233, page 23Additionally, IRBH provides data indicating that patients who originatefrom outside of the state have much longer average lengths of stays whencompared to Florida and District 7 residents. Please see the chart below.8

CON Action Number: 10233Devereux Average Length of StayBy Patient Origin CY 2013Patient OriginationBrevard CountyDistrict 7 TotalFlorida TotalOutside FloridaTotalAverage Length of Stay (Days)150.5139.6265.8390.8347.7Source: CON application #10233, page 23IRBH concludes that if Devereux garners additional out-of-stateresidents, its occupancy could increase significantly due to these longlengths of stay. The applicant feels this would leave even less capacity toserve District 7 residents in need of this level of care.IRBH states that Brevard County is the second most populous county inDistrict 7, with nearly 105,000 children and adolescents for CY 2014, or18.5 percent of District 7’s total child and adolescent population. IRBHexpects this cohort to increase by 5.7 percent or by 32,000 children bythe second year of operation (2018) of the proposed project.The chart below contains the population estimates for the total child andadolescent population (age 17 and younger) in District 7 for January2014 and the January 2020 planning horizon.Brevard County, District 7 & State PopulationAge 17 Years & Younger ProjectionsJanuary 2014- January 2020AreaJanuary 1, 2014January 1, 2020PercentChangeNet IncreaseBrevard CountyDistrict 7State of 3772.87%8.43%5.57%3,00347,404225,963Source: Florida Agency for Health Care Administration Population Estimates, September 2013As shown above, District 7’s population age 17 and younger is expectedto experience 2.86 percent faster growth than the state overall.The applicant presents the following table illustrating District 7 child andadolescent psychiatric discharges from a hospital or IRTF with licensedpsychiatric beds by patient origin and facility. The applicant states thatwhile Brevard County has the second greatest child and adolescentpopulation of the four counties in District 7, it has the fewest number ofpsychiatric discharges at 4.1 percent.9

CON Action Number: 10233District 7 Child and Adolescent Psychiatric Dischargesby Resident County and Licensed ProviderAges 0-17 CY 2013Resident County:Licensed ProviderDevereux Florida (IRTF)University Behavioral Center HospitalCentral Florida BehavioralLa Amistad (IRTF)South Seminole HospitalNemours Children’s HospitalOut of AreaTotal DischargesPercent of TotalBrevardOrangeOsceolaSeminoleDistrict 06100.0%Source: CON application #10233, page 26IRBH points out that the only four Brevard County residents who stayedin Brevard for treatment went to an IRTF (Devereux). According to theapplicant, this means 100 percent who sought acute treatment at apsychiatric hospital migrated out of the county.IRBH indicates that Brevard County resident child and adolescentpsychiatric discharges fluctuated between 91 and 118 during the pastthree years with only between two and four discharged from within thecounty each year (from Devereux).The applicant states that Brevard County’s child and adolescentdischarge use rate is lower than any other in District 7. IRBH points outthe next lowest -- Osceola County -- is still more than twice as much asBrevard County’s. Additionally, it is the 12th lowest of Florida’s 67counties. Please see the chart below for CY 2013. Rankings for thecounties indicate their relation to other Florida counties. The lower therank the lower the discharge use rate.Child and Adolescent Psychiatric Discharge Use Rateper 1,000 Population & Ranking Ages 0-17 CY trict inoleSource: CON application #10233, page 2910District 7

CON Action Number: 10233Applying the discharge use rates of District 7, District 7 less BrevardCounty, and the state’s average, the applicant finds total child andadolescent psychiatric discharges could range anywhere between 451and 532 Brevard cases if Brevard County had equal access to child andadolescent psychiatric beds, compared to only 99 currently. Please seethe table below.Restated Brevard County DischargesBased on Application of District 7 and Statewide Use RatesCY 2013CountyBrevard County Actual CasesBrevard County Population (2013)Utilization99104,732District 7 Less Brevard, Discharge Use RateRestated Brevard County CasesDifference, Restated vs. Actual5.08532433Florida Discharge Use RateRestated Brevard County CasesDifference, Restated vs. Actual4.85508409Source: CON application #10233, page 30, Agency Inpatient Data Tapes, Florida Population Estimates,September 2013 and NHA AnalysisThe applicant asserts that with the development of available andaccessible beds at IRBH, Brevard County’s child and adolescentpsychiatric discharge use rate will increase to 5.08 -- the discharge userate currently of District 7 less Brevard County. Applying this dischargeuse rate, the applicant predicts market discharges by resident county foreach of the first four years of operation at IRBH, illustrated in the chartbelow. IRBH determines that by 2020, there will be 3,076 District 7child and adolescent resident discharges from psychiatric beds -including 547 Brevard County residents.11

CON Action Number: 10233Forecasted IRBH UtilizationYear One (2017) Through Year Four (2020)Market DischargesBrevardOrangeOsceolaSeminoleDistrict 7Market ShareBrevardOrangeOsceolaSeminoleDistrict 7IRBH In-MigrationIRBH Patient OriginDischargesAverage Length of StayPatient DaysAverage Daily CensusOccupancy RateYear OneYear TwoYear ThreeYear *5,28714.519.6%12,50634.246.2%*While market share is reflected at 50 percent in year one, this is an effective rate applied against theincreased discharge use rate and utilization. This is a by-product of the use rate transitioning during thecourse of the year from the prior less than one to greater than five.**The average length of stay is based on the statewide average and UHS’s experience in District 7.Source: CON application #10233, page 38Also shown in the table above, the applicant predicts IRBH will achieve50 percent market share within Brevard County in 2017, increasing to95 percent by 2019. IRBH maintains this market share will not affectDevereux’s current market share of four percent because of theaforementioned differences in treatment models between the twofacilities.The applicant maintains that its sister UHS facilities (UBC, CFBH and LaAmistad) currently have a greater market share (17.2 percent) in BrevardCounty than any other provider even without nearby operations. Theapplicant expects that current patients from Brevard County utilizing theUHS facilities will shift to IRBH once operational. When calculatingmarket share for Orange, Osceola, and Seminole Counties, the applicantstates the following factors: The plan will help facilitate a greater emphasis on adult services atUBC and CFBH that are driven by the local area need in theirrespective communitiesIRBH will only be the third freestanding behavioral health hospital inthe District and the only one in Brevard CountyIRBH will be the only provider in the district to be solely focused ononly providing services to children and adolescents12

CON Action Number: 10233Also included in the table above, the applicant predicts discharges,patient days, average daily consensus and occupancy rates for the firstfour years of operation of the proposed project. IRBH believes theaverage annual occupancy rate will reach 62 percent in year four ofoperation.The applicant expects nearly half -- 48 percent -- of its patients will beMedicaid HMO in the second year of operation. The forecasted patientdays by payor category are summarized by the applicant in the tablebelow.IRBH Projected Patient Days by PayorYears One and TwoPayorMedicaid HMOBlue CrossCommercial InsuranceOther Managed CareSelf-Pay/Charity CareOther PayorsTotalYear One: 1/1/20172,526604241,6152462735,287Year Two: 1/1/20185,9741,429562,82058064712,506Source: CON application #10233, page 39The applicant indicates that its forecast is conservative, achievingreasonable IRBH market shares while still allowing District 7 providers togrow their volume as needed.The applicant states 96 percent of Brevard County residents who seekinpatient hospital treatment for mental health conditions have no choicebut to leave the county. The only option available within the county is along-term residential treatment and only four Brevard County residentsaccessed that service in 2013.The applicant asserts that there will be no impact on Devereux due to itstreatment model and no overlap in the type of service to be provided atIRBH. IRBH believes the introduction of the proposed beds in BrevardCounty will add new volume to the market rather than take away volumefrom existing District 7 providers. The applicant states approval of IRBHwill only positively affect the Brevard County health care community andexisting behavioral health care infrastructure. In addition, the applicantasserts that the proposed project will allow providers outside the servicearea to better serve other district residents who reside closer to theirfacilities.IRBH indicates that it is committed to working collaboratively with theexisting residential treatment programs both in Brevard County andDistrict 7. Lastly, the applicant indicates its parent company, UHS, is anexperienced provider with a thorough understanding of unique needs forchildren and adolescents confronted with behavioral health disorders.13

CON Action Number: 10233The applicant mentions UHS has a first-hand understanding of theDistrict 7 market as it already provides services within Orange County tothe west, in its two hospitals and one IRTF.The applicant notes it has significant support from the community asevidenced by the numerous letters of support received.2.Agency Rule Criteria:a.Chapter 59C-1.040 (4) (h) 1-4, Florida Administrative Code, containfactors to be considered in the review of Certificate of Needapplications for hospital inpatient general psychiatric services forchildren and adolescents.(1)Applicants shall provide evidence in their applications thattheir proposal is consistent with the need of the communityand other criteria contained in Local Health Council Plans, thedistrict Alcohol, Drug Abuse and Mental Health Plan, and theState Health Plan.The applicant states it is consistent with the needs of thecommunity and other criteria as outlined in the state rules andstatutes. The applicant notes there is currently no local healthcouncil with stated criteria to meet.IRBH believes its proposed project is consistent with the strategiesand action plans established by the Brevard County CommunityHealth Improvement Plan 2013-2016. The applicant says otherevidence that this project is consistent with the needs of thecommunity is provided by the many letters of support from localcommunity leaders. The reviewer notes the applicant included sixletters of support from local elected officials.(2)In order to ensure access to hospital inpatient generalpsychiatric services for Medicaid-eligible and charity carechildren and adolescents, 40 percent of the gross bed needallocated to each district for hospital inpatient generalpsychiatric services for children and adolescents should beallocated to general hospitals.District 7 presently has 24 of 275 (or 8.7 percent) of its child andadolescent inpatient psychiatric beds in general hospitals. Onceall Agency notifications, exemptions and CONs are finalized forproviders adding or reducing this bed type in District 7, the bed14

CON Action Number: 10233count will be reduced to 245. If approved, the proposed projectwould result in a general hospital bed ratio of 24 of 319 (or 5.6percent), which would not be in compliance with this cr

Wekiva Springs Center Treasure Coast Behavioral Health (Approved) Palm Coast Behavioral Health (Approved) The reviewer notes that Gulf Coast Treatment Center is comprised solely of 24 child and adolescent psychiatric beds, with no licensed adult psychiatric beds. UHS also operates residential treatment facilities throughout Florida,