area. These economic benefits would almost certainly go to out-of-the-area Contractors and their subs.

The Landowner.  Presumably there is someone who has the appropriate piece of land available to sell. Assuming that land is approved, or can be approved for such a purpose, the landowner stands to benefit from such a sale.

FORMER ST. HELENS HOSPITAL CLOSURE

My Agency made repeated attempts, spanning some three years, to get the former District Hospital to comply with Oregon State Law, by providing and maintaining an adequate number and level of basic services for an acute care hospital license, That Agency was responsible for establishing the basis for the eventual revocation of St. Helens Hospital license.

At that time there were no special license categories for acute care hospitals. Some were developing into combination hospitals to include some long-term care (LTC) beds (the so-called "swing-bed" concept) as an expedient for generating income from large numbers of empty acute care beds. The beds became empty after hospital lengths of stay and admission rates plummeted, following the development of many outpatient treatment modalities for conditions previously requiring in-patient stays. However, hospitals were creating "swing-beds" under their acute care hospital license, on the principle that a higher-level license permitted lower license category activities to be conducted at that facility. I approved those hospital changes then but probably would not do so now, given the different times, healthcare practices and circumstances.

"SWING BED" CONCEPT NOT APPLICABLE

Theoretically, "swing beds" are sound only when there is a glut of unused acute care beds - "any income is better than none". However, the concept works favorably only one way, from acute to long-term. By definition, a long-term care bed is simply that...it is for long-term care. Acute care beds are required immediately - if the 15 beds of the proposed SHH were switched over to LTC use, how can long-term patients be quickly discharged to permit admission of acute care patients needing urgent care? The 15 beds must be left vacant for acute care admissions.

Use of the "swing bed" theory today, in this instance, is simply a wrong planning theory and appears to ignore the fact that private licensees already in the service area are providing LTC beds. SHH would therefore be competing with the livelihoods of owners of those private nursing homes. Is there a demonstrated shortage of nursing home beds in the area? (and by "area" I mean a far greater area than the market area for acute care beds.) LTC patients are not nearly as likely to want to be located in specific towns or areas, nor is their care usually urgent (if so, they would have been transferred to higher level care facilities on a planned discharge basis.) If there is a demonstrable unmet demand for LTC beds, why are private, for- profit facilities not expanding to fill that unmet need? Is it appropriate for a public entity to compete, at public expense, with the private sector by taking on the provision of LTC beds?

PROPOSED HOSPITAL TO ATTRACT M.D.s AS AREA RESIDENTS

Establishment of SHH is proposed as a way to attract allopathic doctors (M.D. doctors) to staff that hospital and presumably provide some of the high-level care attributed to that type of doctor. However, Oregon state law provides that healthcare facilities may not discriminate in admitting privileges, against doctors graduating from non-M.D. schools of medicine who have other, valid, Oregon "doctor" licenses. A hospital must be equally available to Doctors of Osteopathy (D.O.) Recognition must then be given to the reality that SHH must allow any D.O.s, who apply, to practice in it. That may prove to be a significant deterrent if the hope is to attract M.D.s. (Doctors of Chiropractic medicine (D.C.s) do not have hospital admitting privileges in Oregon.)

Traditionally, M.D.s have been reluctant to accept non-M.D. training as equally valid and have shunned working in facilities that were not 100% M.D. staffed.  Because of this reluctance D.O.s have resorted to operating their own facilities, though very limited "cross-staffing" has occurred in a few instances. There is very recent history of two D.O. hospitals in Portland being unable to sustain themselves due to lack of operating funds because of inadequate reimbursement levels.

It is generally assumed that M.D.s will choose to establish their practice in a community that is supportive of their professional lives; provides an attractive place for them to raise families; where they can live in the style and manner they desire. In