I have made a somewhat cursory review of a consultant's Feasibility Study (Study) that forms the basis for Ballot Measure 5-123 on the 2004 General Election docket. The Study is dated January 17, 2003 and was downloaded from the Hospital Coalition website on September 15, 2004. Any subsequent amendments or changes have not been taken into consideration.

I have also reviewed Oregon Administrative Rules, Chapter 333 (OAR) that govern this proposal and have made some half-dozen phone calls to state agencies to obtain data and confirmation of my analyses.

Although I am only speaking for myself and not for any state or other Agency, in my opinion, (confirmed in principle by all the state agencies to whom I have spoken) this proposal WILL require a Certificate of Need (C/N) and WILL NOT be eligible for an expedited review. The review process for a C/N is quite lengthy and time consuming. In my opinion, the C/N is HIGHLY UNLIKELY to be issued.

The Study states that  "The sequencing of the certificate of need process…identified this task as a major obstacle to successful implementation (of the proposal)…just obtaining the certificate of need places the project in jeopardy...Presumably it would be more difficult to obtain voter approval of an operating levy without first obtaining a certificate of need…the addition of the certificate of need process reduces the likelihood for successful project completion." (emphasis added)

The study goes on to say that if a C/N is required, that the Coalition should consider a legislative remedy. In all my years with the C/N responsibility, there was never a single case where a legislative remedy was obtained to circumvent provisions of the Law for any one facility.

Ballot Measure 5-123 is extremely premature and seeking the permanent tax levy BEFORE the proposal is approved by the State is unfair and improper.

WHO BENEFITS FROM A HOSPITAL IN ST. HELENS?

The people of St. Helens are being grossly misled by claims of the healthcare services benefits to be gained by creation of a new hospital. From my review of the Study and conversations with several persons or entities involved with healthcare, it appears the main beneficiaries of this proposal are:

Legacy Systems.  This organization will benefit substantially from the "gift" of a brand-new hospital facility, built and operated at public expense and to be operated by Legacy under a management contract between that corporation and the Hospital District. Legacy will be free of any exposure to financial risk. Legacy will be able to further allocate to another Cost Center (SHH), a share of its Administration overhead and the operational costs of its Ancillary Services, (Radiology, Pathology laboratories, Nursing, Dietary, laundry, Central Supplies) and Purchasing, Accounting, Human Resources and Financial departments and many other services.

All patients from SHH will be referred to Legacy facilities for further hospitalization or other needed services that are not available or provided at SHH. At public expense, Legacy will effectively have a market monopoly for hospital inpatient and outpatient services from within the service area to the detriment of existing doctors not affiliated with Legacy.

Boise Cascade.  Having a hospital at St. Helens will enable Boise to discontinue or reduce the healthcare services it currently provides at its plants in the area and will allow the Company to pass on those costs to a publicly funded facility.

Private, for profit, Long Term Care Facilities (LTCF).  LTCF Management's endorsement of this proposal highlights the benefits that their patients/residents will derive from the availability of hospital services in St. Helens. The provision of medical care, or ensuring that their residents are enabled to receive such care, is an obligation the facility management assumes when the resident enters into an Agreement or Contract with that facility. The LTCF operators would be relieved of that financial burden and responsibility if a publicly owned and operated hospital becomes available and care is provided at public expense. It is also claimed that pneumonia testing could be carried out at SHH; these tests can perfectly well be conducted in existing local doctors' offices or clinics.

The Contractors.  There would be a one-time benefit to the Contractor and sub-Contractors who build the facility. A hospital is a highly specialized and complex project and I am not aware of any hospital construction company in the St. Helens