STATE AGENCY ACTION REPORT ON APPLICATION FOR CERTIFICATE OF NEED...

STATE AGENCY ACTION REPORT

ON APPLICATION FOR CERTIFICATE OF NEED

A. PROJECT IDENTIFICATION

1. Applicant/CON Action Number

Compassionate Care Hospice of Broward, Inc./CON #10211 2625 Drane Field Road, Suite 4 Lakeland, Florida 33811

Authorized Representative: Ms. Judith Grey

(201) 919-4905

Greystone Hospice of District 10 LLC/CON #10212

4042 Park Oaks Boulevard, Suite 300 Tampa, Florida 33610

Authorized Representative: Mr. Bruce G. Schroeder (813) 675-2352

Seasons Hospice & Palliative Care of Broward Florida, Inc./CON #10213

5200 N.E. 2nd Avenue, 3rd Floor Stein Building Miami, Florida 33137-2706

Authorized Representative: Mr. Todd A. Stern (847) 692-1127

2. Service District/Subdistrict

Hospice Service Area 10, Broward County

B. PUBLIC HEARING

A public hearing was not held or requested regarding the proposals to establish a hospice program in Hospice Service Area 10. However, letters of support were submitted, as discussed below.

CON Action Numbers: 10211, 10212 & 10213

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Letters of Support

Compassionate Care Hospice of Broward, Inc. (CON application #10211) submitted 25 letters of support, signed and dated during

November 13 through December 10, 2013. Three letters were undated. Three additional letters were received by the Agency, all signed and dated December 17, 2013. A summary of these letters is included below.

Four elected officials (three from Broward County) submitted a letter citing need for hospice services due to the elderly population of Broward

County and discussed the experience of Compassionate Care service diverse populations. The specific multi-cultural communities cited in the

letters included the Jewish, Cuban-American and African American communities. These letters were signed by:

Peter D. Hernandez, Commissioner, District 2, City of Hollywood

Michele Lazarow, City Commissioner - Hallandale Beach

Anthony Sanders, City Commissioner - Hallandale Beach

Elsa Vazquez, City Commissioner - West Miami, Florida.

Richard J. Lemack, Town Administrator for Davie, Florida also signed the above referenced letter.1

Manny Linares, CEO of North Shore Medical Center in Miami and Florida Medical Center - A Campus of North Shore in Broward County, writes

“we understand there is a 900 to 1,000 admission gap between AHCA’s forecasted 2015 hospice utilization based on actual statewide penetration rates and actual 2012 hospice experience in District X. A large

contributor to this shortfall is the cultural difference in Hispanic populations as well as the use by many of the physicians of hospice services related to non-cancer patients.” Mr. Linares indicates

Compassionate Care has a positive record working with minority groups and has experience caring for end-stage heart failure patients in the

Cardiac Connections program. He states “I understand the Cardiac Connections program is so successful that it has an astounding readmission rate of just 1 percent in the past few years”. Mr. Linares

believes the Broward County community will benefit greatly from approval of the proposed Compassionate Care project.

Randy Gross, CEO of Plantation General Hospital in Broward County, states that “Compassionate Care Hospice is an experienced high quality

provider of hospice care and end of life services and is currently operating in 12 states. They currently have three existing licensed and

1 Mr. Lemack, is appointed by the Town Council per the Town of Davie website at http://www.davie-

fl.gov/Pages/departments.

http://www.davie-fl.gov/Pages/departments

http://www.davie-fl.gov/Pages/departments


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approved hospice programs in Florida, including a program that is approved in neighboring Miami-Dade County…I urge you to approve

their Certificate of Need application”.

Victoria Samuelson, CEO of Hallandale Medical Center in Broward County, believes the growing elderly population in Broward County presents an increased need for hospice care in this area. Ms. Samuelson

writes “As a Board Certified Geriatric Center, I would be honored to welcome Compassionate Care Hospice to Broward County and our community, and would assist them in networking with other health care

providers in our area”.

Robert Linder, CEO of Borinquen Health Care Center, Inc., states that his facility is a Federally Qualified Health Center, and as such provides care to low income residents with limited access to health care services.

Mr. Linder states that “Broward and Miami-Dade have large Hispanic populations, and a large majority of our patients are Spanish speaking.

In our most recent year we served 28,000 patients, with over 80,000 clinic visits. We are also a major provider of health care services to HIV/AIDS clients…we would welcome the opportunity to coordinate with

Compassionate Care Hospice for the care of terminally ill patients should they be approved for a CON.”

Administrators and officials from five assisted living facilities located in Broward County submitted letters of support for the proposed project.

These letters noted the quality of care and positive reputation of Compassionate Care as key reasons for project support, and were submitted by the following:

Aimee Garden-Fernandez, Administrator, Seaside Retirement Resort

Greg Anderson, owner of Azalea Gardens Assisted Living, and Managing Member of Timeless Life Care

Rita Martin, Administrator, Camelot Court Inc.

Deborah Herman, Administrator, Coolidge Palms Assisted Living

Resort

Doreen Campbell, Administrator, Angle House Assisted Living, Inc.

Jeffry W. Vones, Medical Practice Administrator of Healthy Hallandale

Medical Center, cited the growing elderly population in his community as need for additional quality end-of-life care options, and pledged to assist

Compassionate Care Hospice in networking efforts with other health care providers in Broward County. Leona Liss London, board member of the Kidney Association of South Florida, stated that she would be willing to

enter into contractual arrangements with Compassionate Care to provide


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General Inpatient level of services2. Others who support the project include:

Stephanie Swerdlow, LCSW and Geriatric Care Manager at Elder

Options, Inc.

Dr. Nancy Loft, DC, Natural Alternatives to Medicine

Dr. Martin N. Zalac, Chairman, Department of Dermatology, Herbert Wertheim College of Medicine, Florida International University, and

Director, Greater Miami Skin and Laser Center, Mt. Sinai Medical Center

Connie McKenzie, RN, CMC, Director of Firstat RN Care Management Services

Deborah H. Charron, CIC, Senior VP and Healthcare Practice Leader at Marsh & McLennan Agency

Dr. Robert Selz, DDS, MS, practitioner of Geriatric Dentistry and Prosthodontics

Dr. Judith Selz, RN, with a MSW and PhD in social work.

Five members of Broward County’s religious community submitted letters of support. These letters cited the need for hospice services in aging and multi-cultural Broward communities. Fred Stock, MSW,

President and CEO of Jewish Community Services of South Florida, states his organization is the largest non-profit Jewish social service

agency in south Florida. He writes that “I am familiar with hospice care and the Medicare requirement that pastoral care be a component of the provided services. There is a large Jewish population in Broward County

that would benefit from a hospice program designed to address Jewish tradition with respect to end of life issues. It is my understanding that the Founder and CEO of Compassionate Care Hospice is an ordained

Rabbi and they have hospice programs in other states that are accredited by the National Institute for Jewish Hospice (NIJH). The emphasis of

Jewish Hospice is on developing humane palliative strategies that are tailored to the needs of Jewish individuals. My understanding is that if approved to provide such services in Broward County, Compassionate

Care Hospice will attain similar certification. JCS looks forward to having a Jewish Hospice to refer its constituents to in Broward County

and anticipates development of a collaborative relationship with CCH.” Rabbi Edward Davis of Young Israel of Hollywood-Ft. Lauderdale Florida,

an Orthodox synagogue in Broward County, writes “I am familiar with hospice care and the Medicare requirement that pastoral care be a component of provided services. Despite the large Jewish population in

2 The reviewer notes that Ms. Liss-London does not appear to represent a facility; thus it is unclear

what contractual arrangement she is referring to.


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Broward County, it is surprising that none of the established hospices in our county provide a program designed to address Jewish tradition with

respect to end of life issues.”3

Rabbi Raphael Tennenhaus, Executive VP and Director of Chabad of South Broward Headquarters, “which oversees 12 Chabad Centers in Broward County and 45 agencies at our headquarters in Hallandale

Beach”, states that he is “in support of Compassionate Care’s efforts for a Certificate of Need in Broward County, and trust they will work hand in hand with the Orthodox Rabbinical Board of Broward and Palm Beach

Counties.”

Additional letters from the religious community were submitted by:

Pastor Aldo Felipe of the Potential Church in Hallandale Beach,

Florida

Reverend D.L. Poitier of Victory Christian Center in Hallandale.

Greystone Hospice of District 10 LLC (CON application #10212)

submitted 13 letters of support, signed and dated during November 20 through December 17, 2013. One letter was unsigned. One additional

letter was received by the Agency. The following is a summary of these letters.

Six of the letters were from hospitals; three from health care programs, one from a HSA 11 hospice program, one from a national hospice organization, two from Broward physicians and one from a Broward

resident.

Barbara Yanez-Artiles, MSHA, NHA, Executive Director of Wilton Manors Health and Rehabilitation Center in Broward County, states that she will be willing to enter into contractual arrangements for inpatient hospice

beds with Greystone Hospice if the project is approved. A letter of support was submitted by Dr. Wilfred McKenzie, the Medical Director of

the same facility. Joel H. Snook, CFO of Westchester Healthcare Network, a chain of

hospitals in Miami-Dade County, writes that he has “worked with Greystone for several years and continue to be impressed with their

3 VITAS Hospice, a licensed provider in Hospice Service Area 10, is noted to have three Florida hospice

programs certified by the National Institute for Jewish Hospice per this organization’s website at

http://www.nijh.org/. The applicant included the NIJH list for December 2012 –December 2013,

which indicates Compassionate Care Hospices in Pennsylvania and Wisconsin programs were accredited. NIJH’s website shows Compassionate Care Pennsylvania is the one Compassionate Care

program so designated for December 2013 – December 2014.

http://www.nijh.org/


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professionalism and corporate culture which focuses on being patient driven and a good community partner. I can honestly say that I have

never seen an organization that cares so much for its patients.”

Ben Rodriguez, CEO of Hialeah Hospital, states “as you may or may not be aware, Greystone has designed the Greystone Healthcare Network. As I have worked with Greystone in the skilled nursing facilities division,

being able to add Hospice to their portfolio will truly bring the whole concept of a network of healthcare all under one roof and in my opinion provide a much improved care delivery system.”

Myrna Barreto and Ms. Caroline Habbert, Directors of Case Management

at Select Specialty Hospital-Miami and Mount Sinai Medical Center respectively, write that they would be “pleased to work with Greystone Hospice.” Similar sentiments were expressed in letters submitted by:

Shed Boren, CEO of Sister Emmanuel Hospital

Aida Del Rio, Director Clinical Utilization Services at Palmetto General Hospital.

Chris Bredbenner, Executive Director at Gentiva Hospice (Hospice

Service Area 11) attests to the patient and community oriented spirit of Greystone, and Amy Tucci, President of Hospice Foundation of America (HFA), writes that “If Greystone Hospice’s application for a CON is

approved, HFA is prepared to continue its work on behalf of the hospice care philosophy with Greystone Hospice”.

Physicians Robert L. Reeder and Stephen Renae, both doctors practicing in Broward County, attest to the quality of their professional experience

with Greystone Healthcare Management and their confidence that Greystone would bring much needed high quality hospice care to the Broward community. Similar sentiments were shared in letters from

Fred Dumenigo, Executive Director, AmeriCare Renal Center and one resident.

Seasons Hospice and Palliative Care of Broward Florida, Inc. (CON application #10213) submitted 111 letters of support, signed and dated

during April 9 through December 12, 2013. Seven letters were undated and one was unsigned. One additional letter was received by the Agency, signed and dated December 4, 2013. A summary of these letters is

included below.

Fifteen letters were received from hospitals and nursing homes, including two letters of interest to contract for inpatient beds. The latter were submitted by Barbara Yanez-Artiles, NHA, MSHA, Administrator at

Wilton Manors Health and Rehabilitation Center in Fort Lauderdale and


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Gavin Malcolm, LCSW, Regional Manager Case Management at Broward Health North. Mr. Malcolm acknowledges that he personally does not

have the authority to execute an inpatient bed contract.

Frank Python, President of Boca Raton Regional Hospital indicates his facility is a leading provider of healthcare services in “southern Palm Beach County with clinics that extend through Broward”. He states that

“from what I have heard from my colleagues in Dade County, where Seasons currently serves patients, their hospice teams provide amazing compassionate, effective, and responsive care to their dying patients and

their families. It is my belief that, specifically, their open access program would be a much needed benefit for patients needing therapies for

hospice conditions, like blood transfusions and oral chemotherapies that other hospices would not even consider”.

Dr. Ashwin Mehta, U-Health Sylvester at Deerfield Beach, Medical Director of Integrative Medicine and Assistant Professor of Clinical

Medicine at U-Health (University of Miami Health System), states that “as a medical director for one of the leading providers of healthcare services in Broward and Dade counties, I recognize the opportunities to provide

patients and families choices when making a decision for hospice care”. He writes that because of the specialized programs offered by Seasons (diverse holistic, cultural, and medical programs such as Open Access,

“A Touch for All Seasons” dementia program), “I would like to see them (Seasons) being offered as one of the choices for our patients and their

families to consider when needing hospice care here in Broward County”. Other support letters submitted that cite Seasons’ programs include:

Mercedes M. Mukati, LCSW, Department of Veterans Affairs cites Seasons’ participation in the We Honor Veterans program and states

her organization has been working with Seasons over the past few years in Miami-Dade and “they (Seasons) have taken wonderful care

of our veterans”.

John Cavoto, BSW, MS. Ed. Family Consultant-Social Worker at

Broward Health Memory Disorder Center

Eight employees (seven RNs & a pharmacist) at the Holy Cross

Hospital Cancer Center; and

Mark Lacroix, Director of Nursing, The Palms Rehabilitation and

Nursing Center (a 120-bed Broward County community nursing home) also states that he “would be interested in offering (Seasons) as an option to the family of my residents when hospice is needed”.

Edith Lederberg, from the Aging and Disability Resource Center of Broward County, cites the positive relationship over the last 20+ years

that her organization has had with Miami Jewish Health Systems as the basis for her organization’s support. Beth A. Allen, Executive Director of

Joseph Meyerhoff Senior Center writes that after speaking with Seasons


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Hospice staff she “recognized their approach is in line with ours in that they serve the community with care and dignity”.4 Further, the long time

presence of Seasons in Miami-Dade County at Miami Jewish Health Systems “assures me of their ability to provide excellent care”.

Fred Stock, President and CEO of Jewish Community Services of South Florida also states that he recognizes Seasons’ “approach is in line with

ours in that they serve the community with care and dignity”. Further, “the need for quality hospice providers is evident in the community” and he would “like to see Seasons as a choice for seniors to consider when

such a need arises”.

Rabbi Jeffrey Kurtz-Lendner of Temple Solel in Hollywood, indicates that he learned about Seasons from a colleague he has known for many years who serves as a chaplain for Seasons in Miami. The rabbi states that he

is impressed with Seasons’ use of “music therapy, legacy projects and culturally-specific programs such as Kavod HaNefesh for Jewish patients

and Holocaust survivors”. He also states that Seasons has a proud history of serving “members of the community who may be otherwise underserved”. Rabbi Kurtz-Lendner concludes that he “would like to see

Seasons Hospice operate in Broward County and be an option for families and patients” who need hospice care. Rabbi Allan Tuffs of

Temple Beth El in Hollywood signed the same letter with the exception that he has known the Seasons rabbi for over twenty-five years.

John Francis, President and JoAnn Fine of the Margate Chamber of Commerce and Carolyn Morris, Office Manager of the Greater

Pompano Beach Chamber of Commerce

Rev. Samuel L. Wright, PhD, Senior Pastor of Plantation United

Methodist Church

Rev. Tita Calzada, Unity Church of Fort Lauderdale

Angela Aracena, Vice President of Adult Day Services with Easter Seals South Florida, Inc.

Robert Boo, CEO of The Pride Center, indicates his organization is a leader in the provision of services to the local LGBT community. He

states that it is important that hospices provide culturally sensitive services that are free from discrimination to better serve members of

the community and that Seasons has a proud history of serving “members of the community who may be otherwise underserved”. He concludes he would like to see Seasons operate in Broward

County.

4 The Joseph Meyerhoff Senior Center is a beneficiary of the Jewish Federation of Broward County.


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Twenty letters were received from colleges and universities. The majority of these letters referenced the music therapy program for hospice

patients as a reason for their support of Seasons. Four of these were from Florida schools, two discussed placement of social work students

with Seasons and two music therapy. Martine Pierre-Pierre, PhD, LCSW, Director of Field Education, Barry University School of Social Work indicates they have been placing social work students with Seasons for

the last three years. She indicates they have received student feedback indicating that Seasons is a highly regarded organization and cites Seasons’ Leaving A Legacy program. Jennifer Abelott, MS, MSW,

Associate Director, Florida International University School of Social Work indicates they have been placing social work interns with Seasons for

almost a year and indicates that Seasons social workers speak to students in classes about hospice work as well as becoming involved in various training and student assessment activities. She states that

“Such extra involvement is where true commitment is shown”.

Teresa Lesiuk, Ph.D., MT, Program Director and Associate Professor, Music Education and Music Therapy, Frost School of Music, University of Miami, indicates that two of their music therapy alumni are employed

by Miami Seasons Hospice. She states that Seasons’ music therapist “has been instrumental over the years to provide superb supervision to our music therapy practicum and internship students”. She indicates

they will have a student beginning a six month internship with Seasons in January (2014). Jayne M. Standley, Robert O. Lawton Distinguished

Professor, Colleges of Music and Medicine, Florida State University states that “many of our students spend their culminating 6 month internship experiences with Seasons Hospice locations in Miami, Chicago, New

York, etc.” She states that “Seasons Hospice is the largest employer of MT-BCs in the nation and a target employment opportunity for our graduates”. She concludes that Seasons “would be a strong asset for the

Broward community, improving the lives of its citizens and offering outstanding training and employment opportunities.”

Naushira Pandya, MD, Chair of the Department of Geriatrics at Nova Southeastern University College of Osteopathic Medicine, Project Director

of the Geriatrics Education Center and Medical Director of Covenant Village of Florida5 and Avante at Boca, states that Seasons “commitment

to outstanding palliative medicine is remarkable, and their focus on the family and helping residents truly understand the concept of holistic care

5 Covenant Village of Florida has a 60-bed sheltered nursing home (Covenant Village Care Center) in

Broward County.


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shows they value their mission and vision…I would like to work with them through their Compassionate Allies program and our residency and

fellowship programs to further hospice and palliative care in the community”.

Dr. Pandya also states that Seasons’ is a Veteran-centric organization through their national participation in the We Honor Veterans program,

which she “would like to see expanded into Broward County as we serve over forty veterans at the state veteran’s home in Pembroke Pines”. Jacquelyn Browne PhD, LCSW, a full-time faculty member and Professor

of Gerontology at The Institute for the Study of Health, Human Service, and Justice at Nova Southeastern University also discusses Seasons’

“Compassionate Allies” program for students of Gerontology and Geriatrics and indicates the program would be a “welcome option for those who need such care and for those who wish to learn the

humanistic approach in providing care”.

Thirty-five letters were submitted from administrators and employees of assisted living facilities in Broward County. These short letters of a form variety differed primarily in the specific Seasons’ hospice programs cited,

with the most mention given to Season’s “Touch for All Seasons” dementia program. Other Seasons programs mentioned in the letters include Music Therapy, Pets, Leaving a Legacy, Open Access Program,

Veterans, and Jewish programs.

Sixteen letters were received from health care practitioners and health service agencies in Broward County. Many of these letters are of a form variety and indicate that Seasons’ impressive list of programs and

services would be of value to the Broward community. Dante Valdivieso, President of Lightstream Medical6 in Davie, writes that “during 2010 Seasons Hospice partnered with Douglas Gardens-Miami Jewish Health

Systems (MJHS) and has grown from 40 to nearly 400 patients with MJHS being a shareholder. Lightstream Medical, Inc. personally works

with Seasons Hospice and can directly attest to the overall high standards of the company”. Todd Blum, CEO of ENT Associates of South Florida, writes that “as the CEO for one of the largest private practice

otolaryngology groups in the country and a leading provider of healthcare services here in Broward and Palm Beach counties…many of our

patients would benefit from the quality of care provided by Seasons Hospice”.

6 Lightstream Medical, Inc. is a medical equipment supplier per the website at http://medicare-

suppliers.findthebest.com/l/15955/Lightstream-Medical-Inc.

http://medicare-suppliers.findthebest.com/l/15955/Lightstream-Medical-Inc

http://medicare-suppliers.findthebest.com/l/15955/Lightstream-Medical-Inc


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Ten letters were submitted by local businesses and individuals. Many of these letters shared personal stories of hospice experiences elsewhere

which would have been improved upon had the services and programs offered by Seasons been available.

Jason Ibarra, Agency Director at Exults Internet Marketing, notes that “according to the Google Traffic Estimator Tool, as of the month of

October, 2013, people in Broward County searched for hospice care and other queries that include the word hospice an average of 220 times a day. Google Trends scores the category at 52 points in Broward County,

up from a score of 28 points reported for October 2010. This indicates that the search volume has increased by 86 percent in just three years”.

C. PROJECT SUMMARY

Compassionate Care Hospice of Broward County, Inc.

(CON application #10211) is a development stage corporation formed for the purpose of initiating hospice services in Hospice Service Area 10, Broward County. Compassionate Care Hospice of Broward, Inc. (CCHB),

is a wholly owned subsidiary of Compassionate Care Group, Ltd. (CCH). CCH was founded in 1993 and operates 35 programs in 22 states, including one operational (Subdistrict 6B) and two approved (District 11

and Subdistrict 3E) hospice programs in Florida.7 Milton Heching, an attorney, engineer and ordained Rabbi, is the founder and CEO of CCH.

The applicant is proposing total project costs of $142,965 with year one operating costs of $1,559,157 and year two costs of $3,586,231.

Schedule C includes the following conditions:

As required by law, Compassionate Care Hospice is willing to accept any such conditions on its CON-based on any representations made through

this CON application. Compassionate Care will provide all the required components of hospice

care set forth by Medicare Conditions of Participation as well as Florida hospice licensure requirements including the provision of all four levels

of service (routine, continuous care, general inpatient and respite) to all types of patients without regard to race, ethnicity, gender, age, religious affiliation, diagnosis, financial status, insurance status or any other

discriminating factor.

7 Compassionate Care’s CON #10140’s (HSA 3E) termination date is August 26, 2014 and CON #10091’s (HSA 11) termination date was March 26, 2014. Agency records indicate Compassionate

Care’s (CON #10091) HSA 11 program was licensed effective January 13, 2014.


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Specific conditions to be met by Compassionate Care Hospice of Broward

are as follows:

1. The applicant will implement its Cardiac Connections program upon licensure. It will be made available to all eligible residents with a qualifying cardiovascular disease. As part of this

implementation the applicant will ensure: a. The medical director of CCHB Cardiac Connections Program

will be a cardiologist. b. The Cardiac Connections program will have a licensed nurse

practitioner. c. At a minimum, CCHB will hold quarterly meetings for area

cardiologists to maintain open communications with the

community cardiologists to continue to educate them about options in end-of-life care for their patients.

d. At a minimum, CCHB will coordinate with local hospitals’ staff and/or physicians on a monthly basis to review the Cardiac Connections Program and how it may be benefitting

both the hospital and the patient in terms of reduction in readmission rates, program success and other measures to be determined.

e. Cardiac Connection Program patients will receive daily communication from CCHB staff either via an in person visit

or by telephone if an in person visit is not scheduled on a particular day.

f. All Cardiac Connections program patients will have a

Cardiac Comfort Kit with them in their home. g. CCHB will prepare an annual report for AHCA addressing

how hospital readmissions for heart failure have decreased

in the subdistrict relative to the CCHB cardiac admissions.

This will be measured by submission of the annual report as noted and a signed declaratory statement submitted by CCHB to AHCA.

2. Compassionate Care Hospice Group, Ltd. will implement its

Pathways to Compassion Program immediately upon licensure of Compassionate Care Hospice of Broward, which will be made available to all eligible Broward County residents. This will be

measured by a signed declaratory statement submitted by CCHB to AHCA.


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3. CCH will implement its Jewish Hospice Program which is already

accredited by the National Institute for Jewish Hospice (NIJH) immediately upon licensure as detailed within this CON

application. This will be measured by a signed declaratory statement submitted by CCHB to AHCA.

4. CCHB will implement its Hispanic Outreach Program immediately upon licensure as detailed within the CON application. This will be measured by a signed declaratory statement submitted by

CCHB to AHCA.

5. CCHB will work with local Hispanic organizations including Hispanic Unity of Florida, to recruit, train and employ Hispanic personnel. This will be measured by a signed declaratory

statement submitted by CCHB to AHCA.

6. At least 25 percent of all interdisciplinary team members in District 10 consisting of physicians, registered nurses, home health aides, social workers, chaplains and volunteers, will be

bilingual. This will be measured by a signed declaratory statement submitted by CCHB to AHCA.

7. The applicant has conditioned approval of this application on the provision it will become accredited by CHAP upon certification.

This will be measured by CCHB’s submission of its accreditation certificate to AHCA upon receipt.

8. CCHB will provide a Home Health Aide ratio above NHPCO guidelines at an average of 10 hours per patient per week. This will be measured by a signed declaratory statement submitted by

CCHB to AHCA.

9. Compassionate Care Hospice of Broward will not build or operate freestanding hospice facilities in District 10. This will be measured by a signed declaratory statement submitted by CCHB to AHCA.

10. Compassionate Care Hospice of Broward will not participate in

fundraising activities in District 10. This will be measured by a signed declaratory statement submitted by CCHB to AHCA.

Greystone Hospice of District 10 LLC (CON application #10212) seeks authorization to develop and implement a new hospice program in Hospice Service Area 10, Broward County. Greystone Hospice of District

10 LLC is a newly formed development stage corporation authorized to conduct business in Florida. The applicant’s sister corporation,

Greystone Healthcare Management (GHM), provides skilled nursing,


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assisted living and home health care through licensed facilities in Florida and other states since 2001. Operations management, consulting and

customized services will be offered by GHM to the applicant.

The applicant is proposing total project costs of $337,064 with year one

operating costs of $2,770,938 and year two costs of $4,727,017.

Schedule C includes the following conditions: 1. Financial Support - Greystone Hospice of District 10 LLC commits

to establishment of a new nonprofit charitable foundation to assist in meeting the needs of the residents of Broward County. The new

foundation will be funded through $1 million in contributions from Greystone & Co., Inc. during the initial five-year period of hospice program licensure, with at least $200,000 contributed within 90

days of initial licensure of the proposed hospice program. The foundation will be designed to distribute funds based on local

needs as demonstrated through a registered not-for-profit organizations’ current or planned work in the community. An

example of such programs and organization include, but is not limited to:

-United Way -Local colleges for nursing scholarships

-Programs to raise awareness of hospice services -Provision of education and training to clinical and volunteer staff who are involved in hospice care.

-Provision of support or establishment of programs that benefit hospice patients and/or their families that are not otherwise covered as a reimbursed service.

-Provision of education and training to clinicians within the community.

-Reduction of the overall healthcare cost in the community. -Provision of services that might not be otherwise funded or provided.

-Other general purposes, with an emphasis on healthcare that benefit Service Area 10.


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The foundation will be prohibited from making contributions that directly benefit Greystone Hospice of District 10 LLC or any

Greystone affiliate. Compliance with this condition will be measured by submission to the Agency of evidence of the legal

organization of the foundation entity, the restrictions on use of Foundation funds, and an annual itemization of recipients and amounts of distributed funds, including a description of the

specific programs and services funded to benefit area residents in need.

2. Fundraising - Greystone Hospice of District 10 LLC commits that it will not engage in fundraising activities in the service area.

Persons wishing to make donations will be encouraged to donate instead to the newly established foundation (described in Condition #1) or to one of the area’s existing nonprofit hospice

foundations. Compliance with this condition will be demonstrated by submission to the Agency of an annual statement verifying that

this has occurred.

3. Reporting - Greystone Hospice of District 10 LLC commits to

voluntarily report to the Agency’s “Family Evaluation of Hospice Care (FEHC) Satisfaction Survey” found at the FloridaHealthFinder.gov website. Compliance with this condition

will be measured by submission of the requested information.

4. Veterans - Greystone Hospice of District 10 LLC commits to partner with the We Honor Veterans program, which recognizes the unique needs of terminally-ill veterans and their families.

Compliance with this condition will be measured by submission of written acknowledgement from the We Honor Veterans program of the hospice’s involvement.

5. Freestanding Facilities - Greystone Hospice of District 10 LLC

affirms that it will not seek to establish or operate freestanding inpatient hospice facilities in Service Area 10 during the first five years of operation. Compliance with this condition will be

measured by Agency records.

Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON application #10213) is a newly formed entity created for the purpose of establishing a hospice program in Hospice Service Area 10, Broward

County. The applicant’s ownership is the same as that of Seasons Hospice & Palliative Care of Southern Florida, Inc. in Hospice Service Area 11. Miami Jewish Health Systems (MJHS) holds 20 percent of the

applicant’s issued shares and the remaining ownership is shared among other individuals. Management is provided by contractual arrangement

with Seasons Healthcare Management, a national company that will


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oversee compliance with federal and state reporting standards, accreditation, billing, data reporting and other administrative functions.

The applicant states this project represents an expansion into Broward County based on the model of success that Seasons Hospice & Palliative

Care of Southern Florida, Inc. is experiencing in District 11. The applicant proposes a total project cost of $592,610, with year one

operating costs of $3,192,400 and year two operating costs of $6,602,400.

Schedule C includes the following conditions:

1. Seasons Hospice & Palliative Care commits to provide at least two

Continuing Education Units (CEU) offerings per year for registered nurses and/or licensed social workers at no charge through their nationally-accredited CEU programs by the Association of Social

Work Boards and the American Nurses Credentialing Center. The monitoring report for this condition will identify each course, provide a brief description of the content, and the dates and

location of the training.

2. Seasons Hospice & Palliative Care commits to offer internship experiences for positions such as social workers, music therapists, art therapists, bereavement counselors, chaplains, and medical

assistants. We will seek local contracts as well as leverage existing national contracts with the American Music Therapy Association,

Everest College, Kaplan College, and the University of Southern California’s Virtual MSW Program. The annual monitoring report for this condition will include a copy of the advertisements for

interns in Broward County and the number of interns taking advantage of the program.

3. Seasons Hospice & Palliative Care of Broward Florida will donate $25,000 per year to Seasons Hospice Foundation restricted to wish

fulfillment (funding of wishes that enhance quality of life), emergency relief (funding basic needs such as food and shelter), education and research for Broward County residents. The

monitoring report for this condition will be a notarized statement confirming the contribution was made and will identify the check number, date and amount.


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4. Seasons Hospice and Palliative Care commits to provide alternative therapies beyond the core hospice benefit, such as massage

therapy, music therapy, art, or other such alternative therapies when eligible and needed. Seasons shall provide no less than one

full time equivalent (FTE) per 100 patients served on an average daily basis in Broward County. The monitoring report for this condition will identify the number of FTEs by the type of

alternative therapy provided in Broward County.

5. Seasons Hospice & Palliative Care commits to voluntary reporting

of the Family Evaluation of Hospice Care survey to the Agency. The survey report serves as the monitoring report.

The applicant states willingness to add additional conditions should the Agency reviewer decide that such conditions would be of benefit to the

public.

Hospice programs are required by federal and state law to provide services to everyone requesting them and therefore the Agency would not place conditions on a program to provide legally required services such as palliative radiation and chemotherapy and care to the indigent and charity patients. The applicants’ proposed conditions are as they stated. However, Section 408.043 (4) Florida Statutes states that “Accreditation by any private organization may not be a requirement for the issuance or maintenance of a certificate of need under ss. 408.031-408.045.” Also, many of these conditions are required hospice services and as such would not require condition compliance reports. Should a project be approved, the applicant’s proposed conditions would be reported in the annual condition compliance report as required by Rule 59C-1.013 (3) Florida Administrative Code. Section 408.606 (5) Florida Statutes states that “The agency may deny a license to an applicant that fails to meet any condition for the provision of hospice care or services imposed by the agency on a certificate of need by final agency action, unless the applicant can demonstrate that good cause exists for the applicant’s failure to meet such condition”.

D. REVIEW PROCEDURE

The evaluation process is structured by the certificate of need review

criteria found in Section 408.035, Florida Statutes, rules of the State of Florida, and Chapters 59C-1 and 59C-2, Florida Administrative Code. These criteria form the basis for the goals of the review process. The

goals represent desirable outcomes to be attained by successful applicants who demonstrate an overall compliance with the criteria.


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Analysis of an applicant's capability to undertake the proposed project successfully is conducted by evaluating the responses provided in the

application, and independent information gathered by the reviewer.

Applications are analyzed to identify various strengths and weaknesses in each proposal. If more than one application is submitted for the same type of project in the same district (subdistrict or service planning area),

applications are comparatively reviewed to determine which applicant best meets the review criteria.

Section 59C-1.010(3)(b), Florida Administrative Code, prohibits any amendments once an application has been deemed complete. The

burden of proof to entitlement of a certificate rests with the applicant. As such, the applicant is responsible for the representations in the

application. This is attested to as part of the application in the certification of the applicant.

As part of the fact-finding, the consultant, Jessica Hand, analyzed the application in its entirety with consultation from financial analyst,

Derron Hillman from the Bureau of Central Services, who evaluated the financial data.

E. CONFORMITY OF PROJECT WITH REVIEW CRITERIA

The following indicates the level of conformity of the proposed projects with the criteria found in Florida Statutes, Sections 408.035 and

408.037; applicable rules of the State of Florida, Chapter 59C-1 and 59C-2, Florida Administrative Code.

1. Fixed Need Pool

a. Does the project proposed respond to need as published by a fixed need pool? Chapter 59C-1.008, Florida Administrative Code and Chapter 59C-1.0355, Florida Administrative Code.

In Volume 39, Number 189 of the Florida Administrative Register dated

September 27, 2013, a hospice program net need of one was published for Service Area 10 for the January 2015 Planning Horizon. Service Area 10 is currently served by six hospice providers: Catholic Hospice, Inc.,

Heartland Hospice Services, Hospice by the Sea, Inc., Hospice of Gold Coast Home Health Services, Hospice of Palm Beach County, Inc. and VITAS Healthcare Corporation of Florida.

Therefore, the three co-batched applicants are applying in response to

published need.


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Hospice admissions in District 10, Broward County Florida for the

12-month period ending June 30, 2013 are listed by provider in the following chart:

Hospice Admissions in District 10

for the 12-Month Period ending June 30, 2013

Catholic Hospice, Inc. 519

Heartland Hospice Services 240

Hospice By The Sea, Inc. 1,606

Hospice of Gold Coast Home Health Services 453

Hospice of Palm Beach County, Inc. 267

VITAS Healthcare Corporation of Florida 6,017

Total 9,102 Source: Agency for Healthcare Administration’s Florida Need Projections for Hospice Programs for the January 2015 Hospice Planning Horizon, published September 27, 2013.

Compassionate Care Hospice of Florida, Inc. (CON application #10211) states that there are 16 acute care hospitals in Broward County, 35 skilled nursing facilities, 291 assisted living facilities and

hundreds of physicians but only six hospice programs to serve a community with 14,298 annual deaths, of which three out of four

resident deaths are ages 65 and older. The applicant notes that with 271,392 senior residents, Broward County ranks third of 67 Florida counties in elderly population numbers.

The applicant states that regarding the Agency published need computation results for District 10, the most significant numeric gap in

services is within non-cancer cohort age 65 and older, with the next greatest gap in service being the cancer cohort for the same age group; in

aggregate, 70 percent of the projected gap in admissions is within the ages 65 and older age group, demonstrating need for both cancer and non-cancer disease specific end of life care. Additionally, the applicant

notes 287 unserved patients identified in the Agency published need computation are younger than age 65, indicating need for hospice care

amongst all age cohorts.


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District 10 Hospice Utilization

Current Utilization and Projected Need October 2013 Batching Cycle

District 10 Providers U65C 65C U65NC 65NC Total

Projected Hospice Patients 910 2,315 632 6,194 10,051

Catholic Hospice 41 151 12 315 519

Heartland Hospice Services (1) 23 35 17 165 240

Hospice By The Sea 107 453 56 990 1,606

Hospice of Gold Coast Home Health Services

125

92

68

168

453

Hospice of Palm Beach County (2) 19 66 17 164 267

VITAS Healthcare Corporation of Florida 439 1,269 330 3,979 6,017

District 10 Total 755 2,066 500 5,781 9,102

Projected Minus Current 155 249 132 413 949

NET NEED (if Projected Minus Current Hospice Patients >350) 1 Source: CON application #10211, pages 10 and 95. (1) Heartland Hospice Services change of ownership was effective 10/1/11, formerly HospiceCare of South Florida. (2) Hospice of Palm Beach County added Broward to its license effective June 27, 2011.

CCHB notes the hospice penetration rate for Broward County is 61.5 percent, three percentage points lower than the statewide average. The

applicant submits the following chart demonstrating penetration rates among each of the four age and diagnoses cohorts: under 65 cancer, 65 and over cancer, under 65 non-cancer and 65 and over cancer.

District 10 Hospice Penetration Rate Current Utilization and 2010 Deaths

District 10 U65C 65C U65NC 65NC Total

Hospice Admissions 755 2066 500 5781 9102

2010 Resident Deaths 984 2365 2659 8594 14810

District 10 Hospice Penetration Rate

76.7%

87.4%

18.8%

67.3%

61.5%

Statewide

Hospice Admissions 10,590 28,235 7,438 70,908 117,171

2010 Resident Deaths 11,611 29,263 31,754 99,786 181,615

Statewide Hospice Penetration Rate

91.2%

96.5%

23.4%

71.1%

64.5%

District 10 Short Fall (14.5%) (9.1%) (4.6%) (3.8%) (3.1%)

Source: CON application #10211, page 11.

The chart above shows the greatest disparity from the state rate is the under 65 cancer group; in Broward County that cohort has a 76.7

percent penetration rate compared to 91.2 percent penetration statewide. Ages 65 and older with cancer has a high hospice penetration rate

statewide of 96.5 percent but in Broward County only 87.4 percent of all terminally ill residents ages 65 and older with cancer were admitted to hospice.


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Based upon the need analysis, the applicant identifies terminally ill residents with end-stage cardiovascular disease, cancer and other non-

cancer diseases as populations which are in need of hospice services and significantly underserved, which, along with published need, are the

focus of CCHB’s need summary. End-Stage Cardiovascular Disease

The applicant states and reviewer confirms that 57 percent (545 of 949) of the unserved patients identified in the Agency need analysis are non-

cancer cohorts. Per the applicant the 2012 Hospice Annual Report published by the Department of Elder Affairs, reported 11.4 percent of

Broward County licensed provider volume was heart failure patients. CCHB analyzed Medicare claims data to determine the number of elderly deaths in a given year not served by hospice at the time of death, and

concludes that 3,652 elderly persons who died of cardiovascular disease in Broward County were not on hospice service:

District 10 Resident Deaths, Ages 65+

Cardiac Disease Only Versus Total Causes of Death CY 2011

Cardiac Disease

Total Causes of Death

District 10 Resident Deaths, Ages 65+ 3,891 10,645

Hospice Medicare Discharges 861 6,993

Deaths NOT on Hospice 3,030 3,652

Percent of Total Deaths Not on Hospice 77.9% 34.3%

Hospice Penetration Rate 22.1% 65.7% Source: CON application #10211, page 13.

Per the applicant, of the 3,891 elderly residents who died of

cardiovascular disease in 2011, only 861 received end of life care whereas 3,030 residents did not. Thus the hospice penetration rate, or the inverse of those who did not receive hospice care, was only 22.1

percent for those with terminally-ill cardiovascular diseases. Comparatively, there were 10,645 Broward County resident deaths of

those ages 65 and over, of which only 34.3 percent were not on hospice, versus nearly 78 percent of cardiac cases.

Based on Medicare data, the applicant concludes the overall hospice penetration rate was 65.7 percent compared to just 22.1 percent of cardiac cases. If a similar overall hospice penetration rate of 65.7

percent were applied to those with cardiac disease, there would have been 2,556 Medicare discharges from hospice, 1,695 more than were

actually served. CCHB cites the Florida Office of Vital Statistics resident death by disease

category data which shows that in Broward County 36.5 percent of all deaths ages 65 and older are due to major cardiovascular disease, and


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heart failure is a subset of those. The applicant states that nationally, while deaths related to major cardiovascular disease declined, congestive

heart failure deaths increased.

CCHB submits the following two tables demonstrating varying shifts in major cardiovascular disease related deaths for Broward County and statewide. Broward County deaths related to major cardiovascular

disease were 4,648 in 2010, 4,505 in 2011 and 4,643 in 2012 compared to the state’s 53,330, 52,527 and 53,802 during CY 2010-2012, respectively.

In 2011, deaths related to cardiovascular disease declined 5.6 percent in

Broward County, from 4,868 in 2010 to 4,595, followed by a one percent increase between 2011 and 2012. As shown above, a similar trend is evident for the state of Florida.

The applicant notes the 2009 Joint Recommendations by the American

Heart Association and American College of Cardiology for patients with refractory end stage heart failure published guidelines for the proper management of end stage heart patients, which included the

recommendation that “options for end-of-life should be discussed with the patient and family”. In response to this recommendation, Compassionate Care Hospice developed its Heart Connections Program

which provides an option for end stage cardiac patients and their families. This program has been implemented in Compassionate Care

programs across the country where demand for the program has been proven. If approved, CCHB will implement this program to better meet the needs of residents confronted with end stage cardiovascular disease.

Background, End-Stage Cardiovascular Related Diseases

CCHB provides a brief history of the focus of hospice care, which has changed from a model based on cancer care to an increasingly standard

option for non-cancer diseases, including end-stage heart disease. The applicant notes that heart failure is the only major cardiovascular disease with significantly increasing prevalence, incidence and mortality

rates, and is expected to grow as the national population ages. Citing national studies, the applicant concludes that mortality rates for both

heart failure and stroke will continue to rise in the coming decades. Heart failure is the number one reason for readmission in the country.

The applicant submits the following chart showing each Broward County hospital’s specific Medicare heart failure readmission rates, the countywide weighted average and the national rate:


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30-Day Readmission Rates for Heart Failure Patients

Broward County Hospitals and National Rate

July 1, 2009 through June 30, 2012

Hospital Readmission

Rate

Broward Health Coral Springs 25.5%

Broward Health Imperial Point 23.4%

Broward Health Medical Center 22.0%

Broward Health North 25.2%

Cleveland Clinic Hospital 23.0%

Florida Medical Center-A Campus of North Shore 26.0%

Holy Cross Hospital 23.6%

Memorial Hospital Miramar 26.2%

Memorial Hospital Pembroke 24.3%

Memorial Hospital West 25.7%

Memorial Regional Hospital 27.5%

Northwest Medical Center 23.7%

Plantation General Hospital 23.7%

University Hospital and Medical Center 22.4%

Westside Regional Medical Center 24.3%

Broward Weighted Average Readmission Rate 24.5%

National Rate 23.0% Source: CON application #10211, page 20.

CCHB notes that high readmission rates have long been considered a marker of lower quality care. MedPAC’s 2008 recommendation to Congress reported that in 2005, 17.6 percent of all admissions from

hospitals were readmitted within 30 days of discharge. Heart failure is the leading cause for hospital readmissions and the costliest to Centers for Medicare and Medicaid Services, and the applicant notes CMS

penalizes all hospitals for heart failure Medicare readmissions within 30 days of discharge through claims denial or consolidating with primary

admission-to quantify the loss to hospitals and cost savings to CMS, an estimated cost of each hospital readmission is $5,000.

CCHB concludes that based on heart failure readmission rates by hospital provider, the 16 acute care hospitals in Broward County readmitted 518 Medicare fee for service heart failure patients and

another 447 Medicare managed care heart failure patients within 30 days of original discharge, during the 12-month period ending

March 31, 2013. If the estimated cost of $5,000 per readmission is applied, the resulting aggregate reimbursement loss to these hospitals would total $4,827,450 for both Medicare fee for service and Medicare

managed care heart failure readmissions during this 12-month period, and approximately $4.8 million in care provided to total Medicare heart

failure readmissions would not be reimbursed. In addition to the above, in 2012 two Broward County hospitals were

approved by the Agency to establish adult heart transplant programs (Cleveland Clinic Florida Hospital and Memorial Regional Hospital), which will result in more patients seeking treatment of chronic heart


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disease, some of which may be appropriate for hospice care (such as those who receive a left ventricular assistive device). The applicant states

it has extensive experience working with heart transplant candidates and intends to work with both transplant programs once they are

operational. The applicant states that CMS estimates the Cardiac Connections

Program saved CMS $22,000 per patient admitted to CCH, resulting in a net savings to CMS of $77 million during Federal Fiscal Year 2013 and 2014. This is due to the fact that these patients enrolled in end-of-life

care and were treated throughout the rest of their days by hospice. CCH heart failure readmission rates to hospitals are just one percent,

demonstrating the benefit to the CMS system when the industry wide readmission rate is 23 percent. In addition to the benefits to CMS, the Cardiac Connections Program assists individual hospitals in the markets

in which it operates. CCHB states that claims denials for heart failure readmissions are estimated to average $5,000 per readmission,

avoidance of this readmission saves each local hospital. Quantifying the savings at $22,000 per hospice patient savings to CMS, and estimating 200 Cardiac Connections Program patients forecasted for year two in in

Broward County, the applicant projects a CMS annual savings of $4.4 million for the CCHB program in Broward County. Additionally, with 200 Cardiac Connection Program patients having just a one percent

readmission rate instead of 24.5 percent, the overall readmissions of this population would decrease from 49 patients (200*0.245) to two patients

(200*0.01, or a reduction of 47 such readmissions totaling $235,000 (47*$5,000) annually in the second year of operation.

CCHB states Cardiac Connections has provided end-stage heart failure patients with compassionate end-of-life care by breaking the cycle of emergency room visits and hospitalizations, managing the patient’s

anxiety, comforting patients and families, improving patient’s functional status, alleviating shortness of breath and pain.

CCHB concludes that its’ Cardiac Connections Program in District 10 will respond to unserved hospice patients with end-stage cardiovascular

disease, resulting in a cost savings to the existing Broward County health care infrastructure by avoiding readmissions to hospitals and

allowing patients to be treated at home. To enhance access to hospice care for these individuals, CCHB has

conditioned approval of this project on the previously discussed criteria that ensures implementation of the Cardiac Connections Program in District 10.

CCHB forecasts 35.2 percent of its 182 admissions in year one and 45

percent of its 444 admissions in year two of the project will be cardiac


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patients. Based on these assumptions CCHB will admit 64 and 200 cardiac patients in years one and two, respectively. Department of Elder

Affairs data for CY 2012, indicate that Compassionate Care’s 6B hospice admitted 301 patients and 52 or 17.28 percent of CY 2012’s admissions

were patients with end-stage heart disease. The applicant’s overall year one and two projections are similar to the 6B (CON #10036) year one and two projections of 275 and 415 admissions. Compassionate Care (6B)

was licensed in February 2011, began operations in March 2011 and reported 164 admissions in year one (April 2011 – March 2012) and 358 in year two (April 2012 – March 2013).

The applicant includes patient and family testimonials and informational

brochures about the Cardiac Connections Program in Supporting Documents of the application.

Terminally-Ill Cancer Patients

As stated previously, cancer patients comprise 404 of the 949 unserved hospice patients identified in the Agency need analysis, and as a full service hospice CCHB will address the needs terminally ill cancer

patients as well as patients of all ages and diagnoses. The applicant forecasts approximately 25 percent of CCHB patients will be cancer patients, the majority in the 65 and older cohort.

The applicant re-states that there is a 14.5 point disparity between the

Service Area 10 (76.7 percent) and statewide (91.2 percent) hospice penetration rate amongst the under-65 cancer cohort, and a 9.1 percent disparity between the Service Area 10 (87.4 percent) and statewide (96.5

percent) hospice penetration rate amongst the ages 65 and older cancer cohort.

Per the applicant, Broward County cancer deaths increased from 3,349 amongst all age groups in 2010 to 3,405 in 2012, and cancer deaths as a

percent of total resident deaths increased from 22.9 percent in 2010 to 23.8 percent in 2012.

CCHB states that in 2012, 17.2 percent of Broward County residents who died of cancer were not on hospice care (584 of 3,405 total cancer

deaths). CCHB notes that the Agency need publication incorporates 2010 resident deaths rather than 2012 in their calculations. If the Broward County cancer hospice penetration rates amongst both age

cohorts mirrored those of the state, 91.2 percent of the under 65 cohort and 96.5 percent of the 65 and over group, there would have been 3,179 total cancer admissions. This figure is based on 2010 resident deaths;

using 2012 resident deaths there would have been 3,232 total cancer admissions. Using the two different death counts for 2010 and 2012

(3,179 and 3,232), and applying the statewide average hospice


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penetration rates to Broward County deaths by age cohort, the applicant concludes there would have been between 358 and 411 additional cancer

related admissions to hospice than their actually were.

As previously stated, the applicant forecasts 182 total admissions in year one and 444 admissions in year two of the project; 111 (or 25 percent) of year two admissions will be cancer patients, which CCHB states is well

within their patient care capacity. Department of Elder Affairs data for CY 2012, indicate that Compassionate Care’s 6B hospice had 301 admissions and 55 or 18.27 percent of these admissions were patients

with cancer.

The applicant states that it will provide care for all patients, including cancers of all forms and discusses its Pathways to Compassion program, a palliative care program affiliated with Compassionate Care Hospice.

Patients in the Pathways program are not reported to the Agency as hospice patients or admissions. Instead, the applicant states that

Pathways is an effective tool in increasing hospice penetration for cancer patients by acting as a bridge or transition program for people who are not prepared to forego curative care, but will benefit from palliative care.

Its mission is to prevent and relieve suffering and to support the highest quality of life for patients and families, and its philosophy is to allow the patient to make the best healthcare decisions regarding their illness in

an informed and dignified manner. Through education of patients and families and the positive experience of palliative care, hospice comes to

be seen as a valid alternative to a continuum of unnecessary and ineffective continued treatment of a terminal disease. Services provided by Pathways to Compassion include but are not limited to:

Expert treatment of pain and other symptoms

Communication between Pathways to Compassion and patient regarding disease and illness prognosis

Assistance and guidance navigating through the healthcare system

Emotional support for the patient and patient’s family

Improved quality of life.

CCHB concludes that this program will be offered in Broward County as an introduction to hospice, before end-of-life care is necessary or elected

by patients, in an effort to increase hospice penetration rates in this community.

Jewish Terminally-Ill Patients

The applicant states that Broward County has the second highest Jewish population in Florida with 186,275 Jewish persons, based on a 2008


27

survey8. An additional 15,000 Jewish persons reside in Broward seasonally, and Broward County has the fourth largest Jewish

population ages 75 and older and eight largest Jewish total population in the country. The median age for Jewish persons in Broward is 59 years

old. The applicant states the Jewish population is under served by hospice in

Broward County. CCH’s Jewish Hospice Program is accredited by the National Institute for Jewish Hospice (NIJH) and has been implemented in all CCH markets where need for such a program exists. As a result,

the applicant states it is an experienced caregiver who understands Jewish religious ethical directives related to prolonging life and the

hospice benefit. As previously noted, CCH’s CEO is an ordained Rabbi. CCHB intends to accredit the Broward County hospice and reach out to

the Jewish community to educate and enhance market penetration of this population. NIJH has accredited only eight hospice providers in the

state of Florida, and VITAS is the only provider currently accredited by NIJH in Broward County.9

Per the applicant, despite VITAS’ accreditation status, access to Jewish hospice is an issue. Two Rabbi’s provided letters indicating a need for specific Jewish hospice programming in the community. Select portions

of these letters are included in the letters of support section of this report.

CCH states commitment to providing hospice services to the Jewish terminally-ill and their families and is committed to staff education

concerning Jewish traditions, beliefs and cultural values. The applicant lists the extensive guidelines to which a program must comply in order to receive and maintain NIJH accreditation. One CCH program –

Compassionate Care Hospice in Pennsylvania is accredited for Dec. 2013 – Dec. 2014 per the NIJH website.

Hispanic Terminally-Ill Population

CCHB states that Hispanics comprise 27.4 percent of the Broward County population, an increase from 24.3 percent in 2009 to a projected

30.5 percent in 2019. In 2002 Hispanic deaths accounted for six percent

8 CON application #10211, page 32, cites a 2012 study by Dr. Ira M. Sheshkin, Ph.D., Director of the

Jewish Demography Project at the University of Miami and Arnold Dashefsky, Ph.D., University of Connecticut, titled Jewish Population in The United States. 9 The NIJH website indicates the organization has accredited nine hospice programs in Florida (three

are VITAS programs). Compassionate Care is not one of these.


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of all Broward deaths; in 2012 this number increased to 11 percent; Hispanics ages 65 and older account for 15.3 percent of Broward

County’s total over 65 population.

Broward County Resident Deaths Hispanic versus Non-Hispanic Deaths

2002 and 2012

Hispanic Deaths CY 2002 CY 2012 10-Year Change

Ages 0-64 357 465 30.3%

Ages 65+ 623 1,111 78.3%

Total 980 1,576 60.8%

Non-Hispanic Deaths

Ages 0-64 3,474 3,188 (8.2%)

Ages 65+ 11,801 9,535 (19.2%)

Total 15,275 12,723 (16.7%)

Total Deaths

Ages 0-64 3,831 3,653 (4.6%)

Ages 65+ 12,424 10,646 (14.3%)

Total 16,255 14,299 (12.0%)

Hispanic as % of Total

Ages 0-64 9.3% 12.7% --

Ages 65+ 5.0% 10.4% --

Total 6.0% 11.0% --

Source: CON application #10211, page 38.

The applicant submits the above table to show the nearly 61 percent increases in Hispanic deaths across all age groups in Broward County

during the last decade; during the same time frame non-Hispanic deaths decreased by 16.7 percent, evidence of the aging and increasing Hispanic

population in Broward County. CCHB states that analysis of Medicare claims data demonstrates that a

gap exists between Hispanic and non-Hispanic hospice penetration rates in Broward County (4.2 percent versus 95.8 percent of Medicare hospice discharges in 2011). The applicant provides additional data as evidence

of disproportionately low Hispanic hospice utilization in Broward. Compassionate Care Hospice states it has the skill set, experience,

knowledge and capabilities to admit, manage and treat Hispanic patients in a most culturally sensitive way to enhance overall penetration rates amongst Hispanic terminally-ill residents. In area’s with Hispanic

populations, CCH hires bilingual staff and chaplains to provide care in the language patients speak most fluently.

The applicant includes a testimonial from a Hispanic patient family in the Supporting Documents of the application, and provides a brief

summary of four existing Hispanic outreach programs and commensurate Hispanic admissions to hospice; stating that on average,


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the penetration rates of Hispanic hospice patients in these four programs exceed the current percentage of Hispanic hospice cases in Broward

County by approximately six to 16 percent.

CCHB has crafted a Hispanic Outreach Plan to ensure it will enhance hospice penetration rates amongst terminally ill Hispanic patients in Broward County, and has conditioned approval of CON #10211 on the

implementation of this plan and on the provision that at least 25 percent of all interdisciplinary team members in Service Area 10 be bilingual.

Additionally, the applicant will partner with Hispanic Unity of Florida, Inc., the largest not for profit organization in Broward County, in order to

enhance outreach and access to hospice services among Hispanic communities; CCHB will submit a signed declaratory statement to the Agency as a measure of this partnership.

In order to meet the needs of the Hispanic community CCHB also states

intent to:

Conduct education sessions and outreach to inform the Hispanic

community of the benefits of hospice care. The applicant has budgeted for one community liaison FTE and one professional

relationship coordinator in years one and two of the project.

Implement a cultural competency learning program for all CCHB staff.

Implement the previously discussed Compassionate Care’s Pathways to Compassion Program in Broward County.

Applicant’s Unique Programming and Quality Initiatives

CCHB provides a detailed overview of the history, scope and services that comprise Compassionate Care Hospice, a summary of which is given

below. As previously discussed, Compassionate Care was founded in 1993 and

operates 35 programs in 22 states, including one operational (Subdistrict 6B) and two approved (District 11 and Subdistrict 3E) hospice programs

in Florida. For the 12 months ending June 30, 2013 CCH’s 6B program admitted 413 patients, and is on track to admit 440 patients in CY 2013. Compassionate Care’s 6B hospice program (CON #10036 issued

November 2009) was licensed February 22, 2011 but was not operational until March 2011. The program reported 164 admissions during the 12 months of April 2011 – March 2012 and 358 admissions during April

2012 – March 2013. CCH projected that its 6B program would have 275 year one and 444 year two admissions in CON application #10036.

The applicant provides a complete list and map of all CCH entities across the country.


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Mission, Philosophy and Delivery of Services

CCH states its mission is “to affirm life during the final stages by

providing holistic compassionate care to patients and their families; by providing access to hospice care for underserved or difficult to serve populations; by wise and efficient use of available resources and by

educating the community”. CCH strives to provide in-home care, but does have four inpatient hospice units in two states (New Jersey and Delaware). The applicant states that CCH provides a comprehensive

program designed to support both patients and families via an interdisciplinary approach to hospice care. The CCH interdisciplinary

team (IDT) includes members specially trained in providing palliative care. Team members work with patients and families to develop a plan of care that includes bereavement support for families for at least 13

months following the death of the patient. Members of the IDT include:

Patient’s Primary Care Physician Hospice Medical Director

Registered Nurse

Social Worker

Certified Home Health Aide

Therapists

Dieticians

Bereavement Counselors

Chaplains

Trained Volunteers.

The applicant specifies that in addition to the interdisciplinary team roles defined and required by Medicare, CCH also employs personnel unique

to their program:

Nurse Practitioner with a specialty in cardiology-integral to the Cardiac Connections Program and included by CCH as a condition of

approval of CON #10211

Life Enhancement Specialists-paid employees who provide

recreational activities and company for socially isolated patients.

Levels of Care and Setting

CCH provides routine, general inpatient, respite and continuous care to terminally-ill patients either at home or inpatient within a nursing home

or hospital.


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Specific services and programs include:

First Night at Home-designed to ensure new hospice patients receive a little extra support the first days of service

Diagnosis Specific Services-disease specific programs tailored to address illness’s such as cardiac disease, end stage renal disease,

cancer, pulmonary disease, dementia/Alzheimer’s, stroke, liver disease, ALS, HIV/AIDS and failure to thrive

Cardiac Connections

Pulmonary Connections Program-specially designed for those with

cancer, Chronic Obstructive Pulmonary Disease (COPD), Emphysema, Pulmonary Fibrosis and Amyotrophic Lateral Sclerosis (ALS)

Promise Program (End-Stage Renal Disease Program)

Community Outreach

Jewish Hospice Program

Russian Jewish Program

Hispanic Program

Veterans Outreach

Compassionate Care 4 Kids

Volunteer Services

Bereavement Services

Rainbows (Bereavement Support for Children)

Pathways to Compassion

Holistic Therapy Services

Transitions Program

Massage, Music and Energetic Care and Therapy

Sacred Spaces, Comfort Corners, Guided Imagery, Reminiscence

Therapy and Pet Therapy

Palliative Care Program for Correctional (Prison) Medical Services

Educational Training Programs and Compassionate Home Care.

Community Support For CCHB’s Proposal

The applicant also discusses its letters of support for CON application #10211 from hospitals, assisted living facilities, physicians, community

health care organizations, religious congregations and elected officials. A summary of these letters is provided in this report under “Letters of Support”.

Analysis and Impact on Existing Providers

There are currently six hospice providers in Broward County, District 10 (see chart in section E.1.a. of this report).


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CCHB provides a brief overview of each of the six existing Service Area 10 hospice providers and summarizes seven key areas that demonstrate

need for the applicant’s project:

The gap in service within the four age/disease categories previously discussed

949 projected hospice admissions will not be admitted by current hospice providers based on analysis current utilization patterns and

market conditions

Broward County has the 8th lowest hospice penetration rate of 27 total

hospice subdistricts in the state. Two of the seven subdistricts with lower hospice penetration rates have an approved hospice program (3E and 11).

The county’s hospice penetration rate is only 63.7 percent using hospice admissions ending June 30, 2013 and CY 2012 resident

deaths. Statewide, hospice penetration rate is 66.7 percent using the same data points.

Need for a Jewish Hospice Program

Need for a Cardiac Connections Program

Letters of support from existing Broward providers supporting CCH’s proposal to provide hospice care in Service Area 10.

Impact on Existing Providers

CCHB states the proposed project will not negatively impact existing hospice providers. Year two forecasted admissions (444 cases) only

represent three percent of the District 10 deaths forecasted for 2015. However, because the Agency has published need for an additional hospice, the impact on existing providers is not significant.

Why CCHB Versus Other Co-Batched Applicants

The applicant states the small size of CCH allows the company to have much lower overhead than larger corporate chains and can respond

faster to specific needs in the community served. The founder, Milt Heching, is an ordained Rabbi devoted to improving end of life care for all

people. CCHB cites the Pathways to Compassion program, and SA 11 sister program and related 6B program as existing strengths in the Florida hospice community. Regarding the other co-batched applicants,

CCHB states that Greystone Hospice & Palliative Care has little experience in hospice care, and Seasons Hospice & Palliative Care does not have start-up experience providing hospice in Florida.


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Summary and Conclusion

CCHB concludes that is has identified and qualitatively discussed the underserved groups within Broward County and is best positioned to

provide care needed by these populations. The applicant’s year one and two admission forecasts (182 and 444 respectively) and projected age and disease mix are summarized. Admissions under the age of 65 are

anticipated to number 18 in year one and 44 in year two of the project, with cardiac admissions comprising approximately 35 percent (64 cases) of year one and 45 percent (200 cases) of year two admissions. Cancer is

the second largest disease group, forecasted to account for 46 admissions in year one and 111 admissions in the second year of

operations. The applicant restates the 10 conditions based on approval of the

application.

Greystone Hospice of District 10 LLC (CON application #10212) undertook its own needs assessment related to specific conditions in Service Area 10, including research into hospice utilization by patient

race/ethnicity, age and diagnosis, as well as county and age specific mortality rates and trends, and concludes there are no populations within the service area whose needs are being completely unmet. The

applicant concludes that there are ongoing needs that will increase over time however, as the population of the service area increases and ages,

and as the composition of that population changes. Specifically, the applicant states there is an ongoing need for a hospice program committed to meeting the cultural, language and religious needs of the

large Hispanic, Haitian and Jewish communities. Greystone Hospice discusses the service area characteristics which

impact hospice needs which were analyzed by the applicant in order to present the utilization forecast for the proposed program, which is

discussed below. Population Characteristics Impacting Hospice Program Needs in Service

Area 10

The applicant cites Florida Office of Economic and Demographic Research population estimates and forecasts for Broward County and the state.10

10 CON application #10212, pages 13-16.


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Between 2010 and 2015, the total population of Broward County will

increase by almost 50,000 persons, from 1,748,066 to 1,797,981 (a 2.9 percent increase). This is below the stage average, which

anticipates a five percent increase in total population.

During the same five-year period, the ages 65 and over population will

increase by 34,005 persons, from 249,424 to 283,429 (a 13.6 percent change). This is slightly higher than the statewide total population

forecast of 12.5 percent.

The total Hispanic population will increase by 51,350 persons, from

438,247 to 489,597 (an 11.7 percent increase), slightly below the statewide forecast of 12.1 percent.

Greystone Hospice states that by 2015, 27 percent of Service Area 10’s 1.8 million residents are expected to be Hispanic. The applicant cites Pew Foundation research that estimates between 65 and 68 percent of

the U.S. Hispanic population is affiliated with the Catholic Church. Greystone states they are committed to providing hospice care that

considers the language, cultural and religious needs of the Hispanic community, which during CY 2012 accounted for 11 percent of all Service Area 10 deaths. Greystone notes that in addition to the large

Hispanic population, nearly one in three Broward County residents come from a foreign country, with Haitians accounting for the largest of these

populations in Broward County (80,454 persons according to the 2010 Census).

Greystone Hospice also cites data showing that as of 2011 Service Area

10 has the eighth largest Jewish population in the nation. The applicant states intent to become accredited by the National Institute for Jewish Hospice by the end of year three of operations of the proposed project.

Mortality Factors Impacting Resident Hospice Needs

Greystone Hospice states that during CY 2012, 76.3 percent of patients admitted to a Florida hospice were Caucasian; 10.4 percent were

Hispanic, 7.2 percent African American, and the remaining 6.1 percent were uncategorized. During the same year, Hispanic deaths accounted for 11 percent (1,576) of all District 10 resident deaths.

Community Perceptions and Support for Greystone

The applicant reviews the letters of support (discussed previously in this report) in order to conclude that Greystone’ s mission of service to

indigent and low-income populations regardless of race, ethnicity, religious affiliation or ability to pay would be able to serve all segments of District 10’s population.


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Utilization Forecast

Greystone states that the projected admissions for the first two years of operations (January 2015 through December 2016) are based on the

following factors:

Published net need for District 10

The experience and expectations of the most recently approved

provider in the service area.

Utilization of hospice services within the service area by patient age

and diagnosis.

Greystone’s capabilities and readiness to begin operations, as detailed

throughout the application.

District 10 Forecasted Admissions Year One and Two of the Project

Net Need 949

Admissions Greystone

Year One 2015 266

Year Two 2016 357

Both Years Percent

Cancer <65 9%

Cancer 65+ 22%

Non-Cancer <65 6%

Non-Cancer 65+ 63% Source: CON application #10212, page 24.

The applicant states that given the 2015 Agency projection of 10,051 hospice patients in Service Area 10, Greystone’s first year projection of

266 admissions represents just 2.6 percent of the market share, which is both achievable and allows for utilization growth among existing providers.

The applicant also submits the following table showing the projected

payor mix for years one and two of the proposed project:

Greystone Hospice of District 10 LLC Projected Payor Mix

Years One and Two of the Project

Admissions Patient Days

Number Percent Number Percent

Payer

Year One

Year Two

Year One

Year Two

Year One

Year Two

Year One

Year Two

Medicare 240 321 90% 90% 12,351 21,237 93% 93%

Medicaid 17 23 6% 6% 511 879 4% 4%

Commercial 4 5 2% 1% 264 454 2% 2%

Self-Pay 0 0 0 0 0 0 0 0

Indigent/Charity 5 7 2% 2% 133 228 1% 1%

Total 266 356 100% 100% 13,259 22,798 100% 100% Source: CON application #10212 page 25.


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Impact on Existing Service Area 10 Providers

Greystone Hospice states that due to published Agency need for one additional hospice program in Service Area 10, there is no substantive

adverse impact on existing providers. The forecasted admissions (shown above) for Greystone are below the net need published by the Agency; with 266 admissions in 2015, Greystone will leave existing providers with

their current utilization of 9,102 collectively, plus 683 additional admissions11, allowing Greystone to achieve its goal of building a viable new program while allowing existing hospice programs to continue

growing their admissions. However, because the Agency has published need for an additional hospice, the impact on existing providers is not

significant. Summary

Greystone Hospice restates the previously discussed population

estimates and reviews the evidence of cultural and religious diversity in SA 10. The applicant concludes that because it is committed to serving the needs of all Broward County residents, and forecasts achievable and

viable year one and two admissions, Greystone is ideally suited to address the documented need for a new hospice program.

Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON application #10213) states it is closely affiliated with Seasons Hospice &

Palliative Care (SHPC), the 5th largest hospice company in the U.S. Founded in 1997, SHPC currently operates 21 Medicare-certified sites in 15 states, including 10 inpatient centers. Seventeen of these sites are

Joint Commission accredited, which the applicant states intent to apply for in 2014. The applicant states that in 2012, SHPC admitted over 16,000 patients and provided 1,045,200 days of care, as well as $2.8

million in charity care. Also per the applicant, SHPC has utilized electronic medical records for over 10 years, and is the largest hospice

employer of board-certified music therapists in the country. The applicant explains that the mission of SHPC is to honor life and offer

hope, based on five principles that focus on patient care, staff support, creativity, excellence and community awareness of hospice care.

11 The difference between the net need, or “Projected Minus Current”, of 949 and the 266 anticipated

admissions by Greystone in Year One (2015) of the project


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What Factors Lead to Successful Programs with Seasons Hospice & Palliative Care?

The applicant discusses SHPC’s admission trend data in order to

demonstrate that SHPC increased admissions at their 21 nationwide hospices by 60 percent, from 2,569 admissions in the first quarter of 2010 to 4,120 in the third quarter of 2013, due in large part to the

programs utilized by the company. The applicant includes highlights of these programs below.

Elements of Success in Assuring Professionalism Through-Out the Hospice Organization

Existing Seasons Hospices are Joint Commission accredited.

However, Seasons’ SA 11 hospice is not one of them.

Seasons Hospices are members of the National Hospice and Palliative

Care Organization (NHPCO).

Seasons Hospices are held accountable for performance and report to

NHPCO. The applicant details six different reporting measures.

Adoption of and promotion of publications and positions from the

National Ethics Committee to assure staff and volunteers have the widest influence for good in daily service provision

Seasons Hospices employ electronic medical records (EMR).

Seasons Hospices equip and staff 24-hour/7-day a week call centers

with trained responders who have access to EMR so that team members for each patient can be notified as appropriate.

Elements of Success in Programs and Services that Address Core Needs from the Patient-Centered Model

Music Therapy offered only by board-certified music therapists

Leaving a Legacy-a program designed to help patients find purpose and meaning while leaving behind tangible recordings, art works,

journals etc. for family to assist with coping during bereavement

A Touch For All Seasons Dementia Program

Massage Therapy

Volunteer Vigil

Spiritual Presence

Loyal Friends Pet Team

Music Companion

CareFlash-online care support community for patients and families.

We Honor Veterans Program.


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Open Access Services-allows Seasons to fund medical interventions

for patients choosing to continue them so long as their prognosis remains six months or less with the on-going intervention

Bereavement Services including Camp Kangaroo for children, Kavod

haNe’fesh for Jewish patients and families and the Friendly Visitor Bereavement Program for lonely or isolated clients.

The applicant discusses the elements of success specific to training and

workforce development efforts by SHPC, including the previously discussed CEU and internship opportunities, and additional programs that SHPC will bring to the proposed project (Wish Fulfillment Program

and Emergency Care). How Does Seasons Operate?

Seasons Hospice & Palliative Care of Broward Florida, Inc. provides an

overview of their mission, values, and corporate culture. Employee training, onsite corporate visits, and company-wide focus on understanding the needs of the dying are detailed. The applicant states

that education and proper empowerment of employees through corporate involvement help provide hospice patients with the highest quality of

care. Affiliation with Miami Jewish Health System (MJHS)

Per the applicant, Seasons Healthcare Management joined with the Miami Jewish Health System in in 2010 to improve the operations of

Douglas Gardens Hospice. Seasons Hospice & Palliative Care of Southern Florida, Inc., and the applicant are owned by both MJHS and

Seasons, with the latter primarily responsible for operation of the hospice program.

The applicant cites the experience of MJHS, which provides a wide range of community based services in Broward and Miami-Dade Counties as a

key component of the application. These include residents of Broward living at Douglas Gardens North, a MJHS Housing and Urban Development Section 202 facility in Pembroke Pines, and home-based

Broward residents taking advantage of MJHS services through its Program of All Inclusive Care for the Elderly (PACE) or channeling diversion projects, which it contends will benefit from its hospice

program being extended into Broward County. Seasons states that two thirds of MJHS program participants live at home, a central component

of the company philosophy. The applicant provides a map of MJHS facilities in Broward and Miami-Dade Counties.


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Applicant’s Relationship with Seasons Hospice & Palliative Care of Southern Florida, Inc. (SHSF)

As previously discussed, the applicant is comprised of the same

shareholders as SHSF. In order to demonstrate the success of SHSF in Florida, the applicant includes admission trends at Douglas Gardens Hospice in Miami-Dade County, before and after Seasons took ownership

in September of 2010. Douglas Gardens rose from 122 admissions in the fourth quarter of 2010 to 351 admissions in quarter two of 2013.

The reviewer notes that Douglas Gardens Hospice reported 234 admissions for the 12 months ending September 30, 2009 and 238

admissions for the 12 months ending September 30, 2010. The previous two years prior to Seasons ownership. Seasons reported 605 admissions for the 12 months ending September 30, 2011 and 869 admissions for

the 12 months ending September 30, 2012. For the period of October 1, 2012 through June 30, 2013, Seasons reported 900

admissions.12 The applicant discusses how Seasons’ success in SA 11 will translate to

success in SA 10 with the proposed project:

Shared programs that function well in SA 11 will be implemented in

SA 10

The implementation of programs and services already in place allows

employees in SA 10 to be trained by those who work with and use the services of SA 11.

Peer-to-Peer training fosters continued collaboration and problem-solving, enhancing efficiencies and effectiveness, between district

employees.

Ability to transfer patients from one district to another, if necessary,

for example, to bring patients closer to family

Shared management functions will reduce overhead expenses

Partnerships and referral networks in both districts to expand the

environment of Seasons trust in the community and enhance continuity of care for patients.

Why Seasons Hospice & Palliative Care of Broward? Seasons states that it will bring an experienced, enriching, community-based, highly developed and nationally recognized (NHPCO) hospice program to

Broward County that is grounded in demonstrable success by the parent companies in SA 11.

12 Source for hospice utilization data is the ‘Florida Need Projections for Hospice Programs’, published

annually during October 2010 – October 2013.


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Conformity with Fixed Need Pool, Identifying and Reducing Unmet Hospice Need

The applicant cites existing MJHS relationships in Broward County as a

key factor in the ability of Seasons to build a hospice program that meets published need while expanding and improving access to hospice services. As mentioned previously, Seasons states that after assuming

control of the former Douglas Gardens Hospice, admissions increased by 430.6 percent, contributing 900 admissions to the overall growth of 1450 admissions for the service area, making Seasons responsible for 62

percent of the growth in District 11 over a three-year span, demonstrating successful hospice service to the community.

The applicant identifies building a strong workforce as part of Seasons success, accomplished through relationships with colleges, universities,

provision of CEU courses and engaging pre-medical students in their hospice programs. Seasons has conditioned approval of the project on

the provision of internships in Broward County, as well as the provision of CEU’s for registered nurses and/or licensed social workers (see conditions in this report).

The applicant notes that it has letters from Florida International University, Barry University, Temple University, Indiana University-

Purdue University Indianapolis, Texas Woman’s University and Western Illinois University attesting positively to the relationship between Seasons

and in particular students enrolled in Compassionate Allies, a Seasons program that allows pre-medical students to work as volunteers with hospice patients.

Building on Existing Relationships to Serve the Most Frail and Needy

The applicant states during the first three years of operations, the Seasons affiliate in District 11 provided 7.3 percent patient days to

Medicaid, compared to 5.7 percent for other District 11 hospice providers.


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2012 Patients & Percent of Total Patients By Payer, Broward County, and Seasons Hospice &

Palliative Care (Service Area 11)

and Compassionate Care Hospice (Service Area 6B)

Hospice

Medicare

Medicaid

Insurance/ Third-Party

Self-Pay

Uncompensated

Other

Total Patient Days

ESTIMATED BROWARD PATIENT DAYS

Catholic Hospice 29,787 893 374 38 355 6 31,454

Heartland Hospice 351 33 0 4 4 25 418

Hospice by the Sea 84,794 2423 4,473 1,211 280 0 93,180

Hospice of Gold Coast 7,216 2659 1,013 0 1,772 0 12,660

Hospice of PBC 9,523 454 401 21 158 0 10,558

VITAS 523,817 20,681 10,817 224 4708 224 560,472

Broward Total 655,489 27,143 17,078 1,499 7,278 256 708,742

Seasons (SA 11) 85,758 6,981 3,077 0 337 0 96,152

Compassionate Care (6B)

19,806

206

0

0

619

0

20,631

PERCENT OF TOTAL BROWARD DAYS

Catholic Hospice 94.7 2.8 1.2 0.1 1.1 0.0 100.0

Heartland Hospice 84.0 8.0 0.0 1.0 1.0 6.0 100.0

Hospice by the Sea 91.0 2.6 4.8 1.3 0.3 0.0 100.0

Hospice of Gold Coast 57.0 21.0 8.0 0.0 14.0 0.0 100.0

Hospice of PBC 90.2 4.3 3.8 0.2 1.5 0.0 100.0

VITAS 93.5 3.7 1.9 0.0 0.8 0.0 100.0

Broward Total 92.5 3.8 2.4 0.2 1.0 0.0 100.0

Seasons (11) 89.2 7.3 3.2 0.0 0.4 0.0 100.0

Compassionate Care (6B)

96.0

1.0

0.0

0.0

3.0

0.0

100.0

Source: CON application #10213, page 1-25, from DOEA CY 2012 Annual Hospice Demographic and Outcome Measures Report data & Florida Need Projections for Hospice Programs published 3/29/13.

Per the applicant, this amount exceeds the 3.8 percent Medicaid provided by hospice programs in Broward County and the one percent provided by competing applicant Compassionate Care in its respective

service area. The applicant explains that the proposed project will benefit from existing Seasons relationships providing care to the needy established in District 11.

Population Demographics

The applicant identifies residents of ALFs, SNFs, African Americans, persons with HIV/AIDS, end stage renal disease and heart disease as

populations that are underserved by hospice in District 10. After reviewing admissions at existing District 10 hospices and the

Season’s affiliate Douglas Gardens Hospice in District 11 during the past three years, the applicant shows that all programs (except Heartland

Hospice) increased admissions in District 10 (averaging 9.7 percent growth in aggregate) while Season’s affiliate increased admissions at their District 11 facility by 430 percent during the same three-year period.

The reviewer confirms this percent increase. The applicant also discusses existing District 10 hospice programs and Seasons Hospice in


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District 11 by market share, in order to show that patient choice will increase and the market will benefit from the growth and expansion

Season’s Hospice has demonstrated capable of bringing to the adjacent District 11.

The applicant discusses population data for District 10, noting future growth forecasts, particularly in the ages 65 and over category (in its

table 1-3 on page 1-28 of CON application #10213). Per the applicant, analysis of hospice admissions for Broward County

and Florida by age and cause of death show that Broward hospice programs are enrolling cancer patients in all age cohorts and patients

under age 65, at rates below the state average. Similar analysis by the applicant of penetration rates for Broward County demonstrate lower penetration rates in the county compared to the statewide average (0.623

versus 0.680).

Seasons Hospice concludes that the general population of Broward County, in all age disease categories, is being under served by existing hospice providers.

Specifically, the applicant states that hospice admissions for populations over age 65 can be improved through education and outreach with

assisted living and nursing home facilities, an area of focus by the applicant.

Hospital Death Rates The applicant presents data to conclude that gaps in Broward County hospice enrollments are not explained by higher rates of in-hospital deaths for certain ethnic or racial groups, as the number of in-hospital

deaths per 1,000 resident deaths is below that of the state for all reported races or ethnic groups. Seasons Hospice concludes hospices

must find ways to reach out into the communities instead of rely on hospital referrals.

Can hospice Service to ALF’s and SNF’s be improved?

Seasons Hospice states they have done a better job providing service to residents of ALF and nursing homes in comparison to the proportionate share of existing hospice provider’s service to these populations. Per the

applicant:

97 percent of Seasons District 11 admissions during the 12 months

ending June 30, 2013 were ages 65 and over

Seasons reported 38,460 patient days for ALF residents, 40 percent of

the total (96,152 days)


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Broward hospice programs combined reported 412,280 patient days

for ALF residents, or 30 percent of the total (1,384,020 days)13

Seasons Hospice states the competing applicant, Compassionate Care

Hospice that currently operates in Service Area 6B, reported 5,956 patient days for ALF residents, or 29 percent of the total (20,631 days), below the level currently provided in Broward County,

indicating no increased service if this provider is selected.

The following chart is submitted to demonstrate the above findings14:

2012 Patient Days and Percent of Total Hospice Days

By Location of Service for Hospice Programs

Operating in Broward County, Seasons Hospice, Compassionate Care & Florida

Hospice

ALF

Hospice Patient Days

SNF


ALF

Percent of Total

Days

SNF

Percent of Total

Days

Total


Total Percent of Days

Catholic Hospice 5,875 4,538 18.7% 14.4% 31,454 100.0%

Heartland Hospice 200 64 47.8% 15.3% 418 100.0%

Hospice by the Sea 26,783 15,255 28.7% 16.4% 93,180 100.0%

Hospice of Gold Coast 321 961 2.5% 7.6% 12,660 100.0%

Hospice of PBC 2,664 1,396 25.2% 13.2% 10,558 100.0%

VITAS 198,965 107,090 35.5% 19.1% 560,472 100.0%

Broward Total 234,809 129,304 33.1% 18.2% 708,742 100.0%

Florida 1,783,377 1,718,891 21.2% 20.4% 8,429,742 100.0%

Seasons (11) 38,460 18,271 40.0% 19.0% 96,152 100.0%

Compassionate Care (6B) 5,956 1,827 28.9% 8.9% 20,631 100.0% Source: CON application #10213, page 1-35.

The applicant speculates local identity matters with respect to end-of-life care in ways that may impact enrollment:

Catholic Hospice’s identity with parishes and the broader Catholic

Churches may explain their high percentage of patients residing at home

Heartland Hospice’s higher percentage of nursing home patients reflects affiliations with HCR-Manor Care, a national nursing home

provider.

Hospice of the Gold Coast has a high percentage of patients in the

hospital, perhaps reflecting its ownership by the North Broward Hospital District.

13 Seasons Hospice notes that several Broward hospice programs operate in other service areas and

are included in these figures. 14 From the 2012 Annual Hospice Demographic and Outcome Measures Report available through

Department of Elder Affairs; the applicant notes categories provided in that report have been collapsed

into the following: Home=private residence and family care; SNF=inpatient and non-inpatient beds;

Hospital=dedicated hospice and other than dedicated hospice. Also, since several hospices operate in multiple areas and only the hospice program totals are reported, data has been weighted according to

2012 admissions data reported.


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The applicant states that residents in ALF’s and SNF’s do not have the same access with respect to hospice services. These residents form a

subset within communities that are under-served. Seasons Hospice states they can improve service to ALF and SNF residents in this area as

demonstrated by their performance in District 11:

Source: CON application #10213, page 1-36.

Per the applicant, Seasons Hospice not only shows evidence of improvement in service to those in nursing homes and ALFs in District

11, the national organization as a whole has experience providing care in these settings, and submits data demonstrating their care in each setting15.

The applicant reviews excerpts from 12 ALF providers in support of the

proposed project. Are Hispanics Accessing Hospice Care in Broward?

The applicant states that hospice programs in Broward County reported

3,111 Hispanic hospice patients, or 15 percent of 21,372 total hospice patients for 2012; during the same time period Hispanics comprised 11 percent of Broward County deaths. Seasons Hospice concludes that

Hispanic populations are accessing hospice care and Seasons Hospice is experienced serving this population in adjacent District 11.

15 CON application #10213, page 1-37.


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Can Hospice Enrollments for African Americans be Increased? The applicant states that while African Americans comprised 15.6 percent of Broward County deaths in 2012, they accounted for only 8.5

percent of hospice patients in the same time period. In order to promote diversity the applicant conditions the project to the

appointment of at least one African American board member, as well as at least one Hispanic and Jewish member as well.

The applicant notes that it has letters from members of diverse religious and cultural organizations in Broward County who support the project.

Additionally, the applicant provides national data demonstrating diversity among populations who receive care from Seasons Hospice affiliates (CON application #10213, page 1-43).

Does cause of death explain the gap in hospice enrollment?

Per the applicant, the top five causes of death in Florida are the same (in a different order) for Broward County: cancer, heart disease, chronic

lower respiratory diseases, unintentional injury and stroke. The applicant states experience providing care for these populations.

Can hospice enrollment be improved for persons with AIDS, heart disease and renal failure?

The following chart is submitted by the applicant to show that in 2012 Seasons Hospice in Miami-Dade County reported proportionately more

patients with AIDS, end-stage renal disease and end-stage heart disease than any Broward County provider, and reported proportionately more patients with AIDS and end-stage renal disease than any other hospice

provider in its respective service area, as well as Compassionate Care, a co-batched applicant.


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2012 Patients & Percent of Total Patients By Diagnosis for Hospice Programs Operating in

Broward County, Seasons Hospice, Compassionate Care Hospice & Florida

Hospice

Cancer

AIDS

End-Stage Pulmonary

Disease

End-Stage

Renal Disease

End-Stage Heart

Disease

Other

Total

HOSPICE PATIENTS

Catholic Hospice 149 1 38 8 50 151 397

Heartland Hospice 74 3 1 5 1 335 418

Hospice by the Sea 576 5 156 50 155 647 1,589

Hospice of Gold Coast 203 6 41 9 32 146 437

Hospice of PBC 82 1 27 7 33 108 257

VITAS 1,693 58 546 188 728 2,767 5,981

Broward Total 2,778 74 808 266 999 4,154 9,078

FLORIDA 39,070 490 10,687 2,748 14,192 49,055 116,242

Seasons (11) 219 28 83 62 155 365 912

Compassionate Care (6B) 55 3 39 6 52 146 301

PERCENT OF TOTAL PATIENTS

Catholic Hospice 38% 0.3% 9% 2% 13% 38% 100%

Heartland Hospice 18% 0.8% 0% 1% 0% 80% 100%

Hospice by the Sea 36% 0.3% 10% 3% 10% 41% 100%

Hospice of Gold Coast 46% 1.4% 9% 2% 7% 33% 100%

Hospice of PBC 32% 0.5% 10% 3% 13% 42% 100%

VITAS 28% 1.0% 9% 3% 12% 46% 100%

Broward Total 31% 0.8% 9% 3% 11% 46% 100%

FLORIDA 34% 0.4% 9% 2% 12% 42% 100%

Seasons (11) 24% 3.1% 9% 7% 17% 40% 100%

Compassionate Care (6B) 18% 1.0% 13% 2% 17% 49% 100%

Source: CON application #10213, page 1-47.

Seasons Hospice states that access to hospice care can be improved for all disease categories shown, noting their experience providing care successfully to patients with these diagnoses.

Seasons further demonstrates provision of care to these disease

categories with additional charts identifying care by disease category both in Florida, and nationally through Seasons affiliates.

Can hospice service for Alzheimer’s patients, pediatric patients and veterans be improved?

The applicant discusses programs tailored to meet the needs of each of these populations at Seasons Hospice: A Touch for All Seasons (Alzheimer’s and Dementia), Kangaroo Kids and Camp Kangaroo and We Honor Veterans programs.

Forecast of Hospice Admissions

The applicant submits the following chart forecasting admissions for the first two years of the proposed project:


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Forecasted Hospice Admissions for First Two Years in Service Area 10

And the Expected Number of Admissions to Seasons

Cause of Death

Projected Hospice

Patients 1/15-12/15

Seasons Admissions 1/15-12/15-Year One Market Share 2.25%

Seasons Patient Days 1/15-12/15-Year One

ALOS=52

0-64 65+ Total 0-64 65+ Total 0-64 65+ Total

Cancer 910 2,314 3,225 20 52 73 1,070 2,722 3,792

Other 632 6,194 6,826 14 139 154 743 7,284 8,027

TOTAL 1,542 8,508 10,050 35 191 226 1,813 10,006 11,819

Cause of

Death

Projected Hospice

Patients 1/16-12/16

Seasons Admissions 1/16-12/16-Year Two

Market Share 4.0%

Seasons Patient Days 1/16-12/16-Year Two

ALOS=70

0-64 65+ Total 0-64 65+ Total 0-64 65+ Total

Cancer 915 2,327 3,242 37 93 130 2,563 6,518 9,081

Other 635 6,227 6,862 25 249 274 1,779 17,443 19,222

Total 1,550 8,554 10,104 62 342 404 4,342 23,961 28,303 Source: CON application #10213, page 1-53.

Seasons Hospice states that with experience, marked share could increase and length of stay; per the applicant, Seasons has one of the

longest average lengths of stay (ALOS) of all hospice programs in the state as a result of outreach and education that promotes enrollment of patients earlier during their illness, maximizing patient utilization of

hospice services and improving quality of life.16

Is the Forecast Reasonable? The applicant states the forecast is reasonable, and based on the recent

experience of Seasons in Service Area 11. Seasons notes that aggressive forecasts do not always meet projected volume, and refers to Hospice of Palm Beach County as an example-the applicant forecast 2.9 percent

rising to 6.5 percent market share for the first and second year of their proposed hospice project; in actuality, the project achieved 2.2 percent

and 2.9 percent in the first and second year of operations. The following table is submitted by the applicant in order to demonstrate

Season’s hospice admissions experience in District 11.

Seasons Hospice & Palliative Care of Southern Florida’s

First Two Years of Service in Service Area 11

Prior Year

7/09-6/10

Year One

7/10-6/11

Year Two

7/11-6/12

Douglas Gardens Admissions 209 -- --

Seasons Admissions -- 460* 834

Seasons Increase -- 251 635

District 11 Total Admissions -- 10,296 10,789

16 Seasons Hospice cites the 2012 Annual Hospice Demographic and Outcome Measures Report

available through the Department of Elder Affairs which shows the ALOS for Broward County was 65.0 days; the ALOS for Seasons during the same period was 112.9; Compassionate Care Hospice, a

co-batched applicant, had an ALOS of 81.9 days.


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Seasons Market Share -- 2.4 5.8 Source: CON application #10213, page 1-54.

The first year only includes three quarters of Seasons, with the change of ownership from Douglas Gardens occurring 9/20/10.

Seasons compares its projected utilization to Hospice of Palm Beach County’s year one and two admissions in Broward County and its Miami-Dade experience to conclude that its forecast is reasonable. The CON

reviewer agrees. The applicant states there is no adverse impact on existing providers.

2. Agency Rule Criteria and Preferences

a. Rule 59C-1.0355(4)(e) Preferences for a New Hospice Program. The

Agency shall give preference to an applicant meeting one or more of

the criteria specified in the below listed subparagraphs: (1) Preference shall be given to an applicant who has a

commitment to serve populations with unmet needs.

Each co-batched applicant is responding to published need for an additional hospice program for the January 2015 planning horizon.

Each applicant discusses serving populations they believe to be

underserved. Compassionate Care Hospice of Broward, Inc. (CON application

#10211) commits to meeting the needs of all patients and their families in need of end-of-life care in Hospice Service Area 10. Compassionate Care states that it will serve all patient populations

within the four age/diagnosis cohorts as well as specific underserved populations which include cardiovascular disease

patients, residents of Hispanic decent and residents of Jewish faith.

In addition, the applicant provides a summary of intent to adhere to the Rule 58A-2 Florida Administrative Code criteria.

Greystone Hospice of District 10 LLC (CON application #10212) states that based on its own extensive research there are

no populations within Service Area 10 whose needs are being completely unmet. However, the applicant identifies an expanding population that will present an ongoing need for hospice services

committed to meeting the cultural, language, and religious needs of the large Hispanic, Haitian and Jewish populations and commits

to meeting these specific needs with their hospice program.


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Seasons Hospice & Palliative Care of Broward Florida, Inc.

(CON application #10213) states that based upon its own analysis of the service area, no single variable such as race,

ethnicity, disease category or age group explains the high published need for the service area, and concludes that all groups across the county are not enrolling in hospice proportionate to the

state. The applicant identifies and commits to the provision of internship opportunities and CEUs and to the provision of hospice care to residents of nursing homes in order to expand service and

improve the quality of hospice care in Broward County.

Seasons Hospice submits the following charts to demonstrate its commitment to the provision of care to residents of nursing homes:

Hospice Days of Care Delivered to Residents of Nursing Homes with

Percent of Total Reported Patient Days, CY 2012 Hospice Patient Days NH Patient Days Percent NH

Catholic Hospice 31,454 4,538 14.43%

Heartland Hospice 418 64 15.31%

Hospice By the Sea, Inc. 93,180 15,255 16.37%

Hospice of the Gold Coast 12,660 961 7.59%

Hospice of Palm Beach County 10,558 1,396 13.22%

VITAS 560,472 107,090 19.11%

District 10 708,742 129,304 18.24%

STATE 8,429,742 1,718,891 20.39% Source: CON application #10213, page 2-5.

Hospice Days of Care Delivered to Residents of Nursing Homes with

Percent of Total Reported Patient Days, CY 2012 Seasons Hospice & Palliative Care of Southern Florida And Compassionate Care Hospice of Miami Dade (6B)

Hospice Patient Days NH Patient Days Percent NH

Seasons Hospice 96,152 18,271 19.00%

Compassionate Care 20,631 1,827 8.86% Source: CON application #10213, page 2-5.

The applicant forecasts a 19 percent provision of its total patient days to nursing home residents, or 2,246 patient days in the first

year of operations for the proposed project, rising to 5,377 patient days in year two.

(2) Preference shall be given to an applicant who proposes to provide the inpatient care component of the hospice program

through contractual arrangements with existing health care facilities, unless the applicant demonstrates a more cost-efficient alternative.

Compassionate Care Hospice of Broward, Inc. (CON application

#10211) intends to have contractual agreements with nursing homes and hospitals, as well as other healthcare providers


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designed to meet patient needs in Broward County. Compassionate Care states by partnering with hospitals and

nursing homes to provide hospice inpatient care; it will fulfill its goal to expand awareness and utilization of hospice. The applicant

provides letters of support from Florida Medical Center-A Campus of North Shore and Plantation General Hospital. Compassionate Care Hospice anticipates that it will negotiate contractual

arrangements with hospitals and nursing homes in all geographic areas of the service area.

Greystone Hospice of District 10 LLC (CON application #10212) expects to provide approximately 3.7 percent of its total

patient days to inpatients during the first two years of the proposed project’s operations, requiring 844 general inpatient days of care in year two, the equivalent of 2.3 inpatient beds. The

applicant expects to deliver inpatient care through contractual arrangements with existing health care facilities. The applicant

attests to the experience of its sister organization GHM’s history of making such contractual arrangements (as an operator of assisted living facilities and nursing homes), and includes a copy of the

applicant’s “Policy #A-23.0 Inpatient Care” and Inpatient Agreement documents that will govern it’s approach to inpatient care (Tab 4, CON application #10212). The applicant notes Wilton

Manors Health and Rehabilitation Center submitted a letter of support indicating willingness to work with Greystone Hospice on

this issue. Seasons Hospice & Palliative Care of Broward Florida, Inc.

(CON application #10213) states intent to provide inpatient care through contractual agreements with area hospitals and nursing homes. The applicant includes a letter of commitment to contract

for inpatient beds with Wilton Manors Health & Rehabilitation Center, and a letter of interest to contract for inpatient beds from

Broward Health North in the “Supporting Letters” portion of the application.

(3) Preference shall be given to an applicant who has a commitment to serve patients who do not have primary

caregivers at home; the homeless; and patients with AIDS. Compassionate Care Hospice of Broward, Inc. (CON application

#10211) commits to serving all patients including those who do not have primary caregivers at home, the homeless, and patients with AIDS.


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The applicant states that this commitment is evidenced by Compassionate Care related entities’ history of provision of care to

these populations.

Greystone Hospice of District 10 LLC (CON application #10212) commits to providing care to all individuals eligible for care regardless of their living status or diagnosis. The applicant

reviews the key provisions contained in its policy A-48.0 Caring for Patients with Challenging Social, Environmental or Physical Needs (Tab 4), which features Greystone Hospice’s detailed plan of care

for patients in each of the following circumstances: care for patients without a primary caregiver at home; care for homeless

persons; and care for persons with AIDS. The applicant states intent to provide inpatient hospice services at their own skilled nursing facilities or pay to have it provided in other area hospice

residential care or skilled nursing facilities if the plans to provide this care in area shelters or other alternate locations are

unsuccessful. Seasons Hospice & Palliative Care of Broward Florida, Inc.

(CON application #10213) is committed to serving all patients in need that are eligible for hospice or that could benefit from its Open Access Program, including those who do not have a primary

caregiver at home, the homeless and patients with AIDS.

For patients without a caregiver at home, Seasons details extensive options for the provision of care in locations in accordance with the patient’s wishes. Similarly, the homeless’ wishes will be honored

in regard to what they consider their “home” and arrangements for care will be implemented as appropriate.

The applicant discusses AIDS cases by state and county and states Seasons has a proven track record providing care to AIDS patients

in District 11, and submits the table below:


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2012 Estimated AIDS Patients for Hospice Service Area 11

by Hospice Provider

Hospice AIDS Total Percent AIDS

Catholic Hospice, Inc. 5 2002 0.25%

Heartland Hospice 2 230 0.87%

Heartland Hospice* 3 366 0.77%

Hospice Care of South Florida 0 101 0.00%

Odyssey Healthcare 6 839 0.75%

Seasons Hospice & Palliative Care 28 912 3.07%

Vitas 89 6,252 1.43%

Service Area 11 Total 134 10,918 1.23% Source: CON application #10213, page 2-9. *HospiceCare of SE Florida.

Based on Seasons’ historical three percent service to patients with AIDS in Service Area 11, the applicant anticipates seven AIDS patients in the first year and 12 AIDS patients in the second year

of operations for the proposed project.

(4) In the case of proposals for a hospice service area comprised

of three or more counties; preference shall be given to an applicant who has a commitment to establish a physical

presence in an underserved county or counties. Hospice Service Area 10 consists of one county, Broward. This

criterion is not applicable to this review.

(5) Preference shall be given to an applicant who proposes to

provide services that are not specifically covered by private insurance, Medicaid, or Medicare.

Compassionate Care Hospice of Broward, Inc. (CON application #10211) states it offers a host of special programs and services

that are not specifically covered by private insurance, Medicaid or Medicare. The applicant commits to provide the following non-core

services:

Pathways to Compassion - a palliative care program whose

mission is to prevent and relieve suffering and to support the highest quality of life for patients and families. The program is

not the same as hospice care nor are its patients counted as hospice patients in either state or federal reports. Palliative care may be provided at any time during a person’s illness or

debilitating condition.

Complementary Care Program - services offered in this program are massage therapy, music therapy, energetic care, sacred

spaces, guided imagery, reminiscence therapy, and pet therapy.


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Transitions - a community service program, designed to

enhance the quality of life for individuals and their families facing life-limiting illnesses. Services include emotional support, education, and practical assistance such as running

errands, performing house chores and food preparation. Transitions is a free service provided to eligible

residents/patients and is funded by Compassionate Care Hospice and community donations.

Jewish Hospice Program – Compassionate Care Hospice provides and coordinates resources and services that meet the

needs of the Jewish Community surrounding loss, life’s changes, terminal illness, dying and grief.

Hispanic Hospice Program – Compassionate Care Hospice develops all Hispanic/Spanish speaking interdisciplinary teams

to serve the needs of these patients. All patient informational brochures are available in Spanish and all team members are

bilingual, including chaplains, nurses, social workers and others. Staff is trained on cultural sensitivities and recognizes important Hispanic related dates and events.

Compassionate Care 4 Kids – services are provided in a team

approach to patient care strengthened for Compassionate Care Hospice partnerships with local children’s hospitals.

Life Enhancement Specialists – are paid employees at

Compassionate Care Hospice who provide recreational activities for socially isolated patients. The life enhancement specialist focuses on enhancing the patient’s quality of life by carrying out

various activities such as painting the patient’s nails, playing music, conversing with the patient and keeping this person

company. Schedule 6 provides for one FTE life enhancement specialist.

Cardiac Connections - is a care model developed to meet the unique needs of patients with advanced cardiac disease and

congestive heart failure. Treatment will greatly reduce or eliminate visits to the emergency room and hospitalization.

Promise Program – meets the requirements of needy populations. Compassionate Care Hospice provides a

supportive network of medical, nursing, and psychosocial interventions for patients who may be considering stopping

dialysis treatments.


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First Night at Home – program is designed to ensure new

hospice patients receive a little extra support the first few days on service. Hospice aides are staffed for evening or “off hour” shifts. Weekend personal care support is readily available to all

patients.

Veterans Outreach – will be implemented to meet the end-of-life needs of this patient population by assisting veterans in

accessing available services and supports offered to veterans.

Community Outreach – reaches out to local schools and

supports children experiencing the death of a loved one. Compassionate Care Hospice teams will participate and sponsor

community toy and food drives around the holidays. Compassionate Care Hospice will also partner with local hospitals and health care organizations to reach beyond hospice

and focus on wellness and patient education; and attend and/or host community health and wellness fairs and other

events.

Volunteer Services – trained volunteers will be used to provide

administrative support and direct patient care. Volunteer services will be based on patient need and requests as assessed

by the volunteer coordinator.

Bereavement Services – after a patient has died, the team will keep in contact with the family on a regular basis for at least 13

months after the death of a loved one. The team may provide memorial services in long-term care facilities and assisted living facilities.

Rainbows – is a bereavement support program for children who

are experiencing grief through a death or divorce in the family.

Comfort Corners – is a program in which Compassionate Care Hospice sponsors designated areas within a long-term care

facility and decorates the area to resemble a warm, home-like environment for hospice patients and their families.

Greystone Hospice of District 10 LLC (CON application #10212) states it intends to provide a broad range of services not covered by private insurance, Medicaid or Medicare and will work

with community service organizations to provide care to those people unserved by traditional medical entities such as those with


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too many assets or who are not old enough to qualify for Medicaid or Medicare, or who have lost health insurance due to an inability

to work.

Non-covered services that will be covered by Greystone Hospice include:

Pet Service Support Program that includes assistance with pet care for patients with pets; working with the Humane Society

and animal shelters to find new homes for pets so their owners die with the peace and knowledge their pet will be care for after death, and a pet loss grief support program for anyone grieving

the loss of a pet.

Specialized Alzheimer’s/Dementia Program focused on

improving the quality of life and that of the family members of these patients. The applicant states 12.8 percent of hospice

patients nationally in 2012 had a primary diagnosis of dementia. Greystone staff and volunteers will provide specialized care, attention, and support to these patients and

families and gives a detailed list of such services.

Bereavement and Grief Support Programs available to all

service area residents regardless of their relationship to Greystone Hospice, the applicant details a list of over a dozen

grief support services including Yoga for the Grieving Heart and Weekend Bereavement Camps for Children.

Integrative and Expressive Therapies including music, art,

palliative massage, pet, aroma, reiki, relaxation, imagery, beauticians, manicurist, bedside vigil service and more.

Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON application #10213) conditions the application to the

provision of alternative therapies beyond the core hospice benefit, such as massage, music, art and other alternative therapies, and

will provide no less than one FTE per 100 patients served for this purpose. Details of these programs are listed below:

Music Therapy - a full-time music therapist will be part of this program with more added as the hospice grows, to a census

ratio of one music therapist to 100 enrollees.

Pet Therapy - a specialized program within the volunteer

services that provides specialized training for volunteers with pets who are therapy certified. Scheduled pet visits by therapy

dogs and handlers as noted in patient’s care plan.


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Palliative Care Program - provides clinical symptom

management for people living with an advanced illness and emotional support for the families and caregivers. This differs from hospice care in that it is provided earlier during the

disease process, does not require a six-month prognosis and can be utilized while the patient undergoes other medical

programs and services.

A Touch For All Seasons - a comprehensive program for

patients with Alzheimer’s and other types of dementia. Highly specialized, this program uses person-centered approaches to improve quality of life through meaningful sensory activities,

stimulation, relaxation, comfort and serenity.

Open Access - covers services many other hospices won’t

consider like ventilators at home, radiation therapy and chemotherapy.

Pharmacy Consultant - available 24/7 for all nurses and

physicians to assist in pharmacologic consultation.

Education - external/community education by top speakers to ensure nursing personnel and other professionals earn required

CEU for maintaining licensure and certification requirements.

Kangaroo Kids Summer Support Camp - for bereaved children

that includes a weekend trip with parent/guardian to one of Florida’s theme parks.

Kangaroo Kids - child and family-focused professionals

committed to supporting families who care for their children at home.

Volunteer Vigil Program - direct patient care volunteers who have completed all core volunteer requirements and have six

months active patient care experience. They must be available to be called to service within their defined service area at a minimum of two hour shifts on a regular basis.

Call Center - the new hospice will operate its own call center for

afterhours triage of calls with Seasons Hospice employees who are specifically trained in hospice and palliative care and have access to all patients’ up to date patient information. This

hospice will be fully integrated with Seasons’ national system, which operates 24 hours a day, seven days a week.


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b. Chapter 59C-1.0355, Florida Administrative Code contains the following general provisions and review criteria to be considered in

reviewing hospice programs.

(1) Required Program Description (Rule 59C-1.0355(6), Florida Administrative Code): An applicant for a new hospice program shall provide a detailed program description in its certificate

of need application, including:

(a) Proposed staffing, including use of volunteers.

Compassionate Care Hospice of Broward, Inc. (CON

application #10211): As reflected in Schedule 6A of the application, the following is the proposed staffing for each of the first two years (CY 2015 and CY 2016) of operation.

Position

Average Number

of FTE Year One

Average Number

of FTE Year Two Administrator 1.0 1.0

Professional Relations Coordinator 1.0 1.0

Secretary 1.0 2.0

Community Liaison 0.5 1.0

Clinical Coordinator 1.0 1.0

Medical Director 0.2 0.5

Registered Nurse 2.0 4.5

Per Diem Registered Nurses 0.3 1.0

LPN 0.0 1.0

Per Diem LPN 0.0 0.5

Nurses’ Aides 7.0 14.0

Nurse Practitioner 0.5 1.0

Per Diem Nurses’ Aides 0.4 1.6

Continuous Care Per Diem LPN 0.69 2.07

Continuous Care Per Diem Aide 0.69 2.07

Life Enhancement Specialist 0.2 1.0

Music Therapist 0.2 0.5

Massage Therapist 0.2 0.5

Dietary Services 0.2 0.5

Social Worker 1.0 2.0

Volunteer Coordinator 0.5 1.0

Chaplain 0.5 1.0

Total 19.08 40.74 Source: CON application #10211, Schedule 6A.

The applicant notes the hospice program will operate under

the direction of an administrator; administrative staff, two part time medical directors (one for the overall program and

one for the Cardiac Connections program), and the additional positions listed above comprise local operations that will be supported by CCH corporate staff, as well as the

Florida director of operations and staff.


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Greystone Hospice of District 10 LLC (CON application #10212): As reflected in Schedule 6A of the application, the

following is the proposed staffing for each of the first two years (CY 2015 and CY 2016) of operation.

Position

Average Number

of FTE Year One

Average Number

of FTE Year Two Administrator 1.00 1.00

Director of Clinical Services 1.00 .50

Spiritual Counselor 1.00 .50

Medical Social Worker 1.20 .90

Office Manager (Clerical Staff) 1.20 .80

Billing Clerk .50 .50

Bereavement Counselor .50 .30

Medical Director-Contract 0.15 0.10

Alternate Medical Director-Contract 0.10 0.05

Continuous Care (RNs & HHAs) 5.55 3.99

Hospice Liaison (Marketing)/Patient Care Navigator

1.50 1.00

RNs 3.60 2.60

Hospice Aides/Homemakers 4.50 3.30

Coordinator of Volunteers 0.60 0.44

Dietary Counselor 0.01 0.01

Total FTEs 22.41 14.99 Source: CON application #10212, Schedule 6A.

Greystone Hospice states the staffing ratios are based on the experience of Greystone Hospice’s affiliate organizations in

Florida, and the experience of individuals employed by Greystone Hospice with expertise in hospice management. The applicant notes Schedule 6 does not include volunteers,

which will be vigorously recruited by Greystone, and includes a copy of the job description for the director of

volunteers position listed in Schedule 6 as well as various types of volunteer positions (Tab 6).

Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON application #10213): Schedule 6A shows the following proposed staffing for years one and two of the

proposed project (ending December 31, 2015 and 2016):


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Position Average Number of FTE Year One

Average Number of FTE Year Two

Administrator 1.00 1.00

Admissions 1.00 1.25

Team Coordinator 1.00 1.00

Team Assistant 1.25 2.00

Business Development 1.00 1.25

HR 1.00 1.00

CC Coordinator 1.00 1.00

Clinical Administration 1.00 1.00

Medical Director 0.50 0.50

Physicians, Other: -- 1.00

RNs/LPNs 13.25 33.83

Nurses’ Aides/HHAs 4.50 11.08

Chaplain 1.00 1.67

Social Worker 1.50 2.42

Volunteer Coordinator 1.00 1.00

Music/Art/Massage Therapy 1.00 1.67

Total FTEs 31.00 62.67* Source: CON application #10213, Schedule 6A. *The applicant’s Schedule 6A shows a total of 62.68 FTEs in year two probably due to rounding.

The applicant notes that volunteers are not included in the above schedule, yet will be foundational to the hospice

program, and provides a detailed discussion of the scope and purpose of volunteerism at Seasons and in hospice in general. Per the applicant, volunteers for the proposed

project will provide extensive quality enhancement through services such as companionship, errand running,

homemaker chores, babysitting children in the home, vigil volunteers, pediatric volunteers and bereavement services. Extensive training is provided to volunteers by Seasons, and

volunteers are generally divided into direct patient care and indirect patient care volunteers, the former interacting

directly with patients and families, and the latter providing support services such as administrative, office and computer skill services.

(b) Expected sources of patient referrals.

Compassionate Care Hospice of Broward, Inc. (CON application #10211) states that referrals will come

from area physicians, hospitals, nursing homes, other healthcare providers, family members and patients themselves. The applicant received a number of letters of

support from Hospice Service Area 10 physicians, assisted living facilities, nursing homes, hospitals, other community

organizations and residents.


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Greystone Hospice of District 10 LLC (CON application #10212) includes the following chart detailing expected

sources of referrals:

Source % Of Referrals Hospitals 36%

Physicians 23%

Skilled Nursing Facilities 12%

Patient, Family or Friend 9%

ALF 5%

Home Health Agencies 1%

Churches, Service Orgs., Other 14% Source: CON application #10212, page 36.

Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON application #10213) states that education of

physicians and outreach efforts to long-term care, assisted living and nursing facilities will produce referrals. Additional referrals are anticipated from hospitals, churches and other

health care and community service programs as indicated in the letters of support. The applicant states that referrals will also be expected from: comprehensive medical rehab

facilities, families, individuals, advocates for the homeless and HIV/AIDS patients and area military organizations.

(c) Projected number of admissions, by payer type,

including Medicare, Medicaid, private insurance, self-

pay, and indigent care patients for the first two years of operation.

Compassionate Care Hospice of Broward, Inc. (CON application #10211): The following table delineates

the number of admissions by payer type for the first two years of operation.

Expected Admissions by Payer Type

For Compassionate Care Hospice of Broward, Inc.

Service Area 10 Payer Type Year One Year Two

Medicare 171 418

Medicaid 6 13

Charity 3 8

Insurance 2 6

Total 182 444 Source: CON application #10211, page 108.

As shown in the table above, the applicant intends to serve 182 and 444 patients in its first and second year of

operation respectively.


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Compassionate Care indicates that charity care will be 1.3 percent of admissions in years one and two. CCHB does not

expect to collect any funds on patients it treats during the first three months of operation, between licensure and

certification dates. Greystone Hospice of District 10 LLC (CON application

#10212) provides the following table illustrating its projected number of admissions by payer type for the first two years of operations.

Projected Number of Admissions by Payer Type

For Greystone Hospice of District 10 LLC

Service Area 10 Payer Type Year One Admits Year Two Admits

Medicare 240 321

Medicaid 17 23

Private Insurance 4 5

Indigent/Charity 5 7

Total 266 356 Source: CON application #10212, page 37.

Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON application #10213) submits the following chart

showing projected admissions and patient days for years one and two of the project:

Seasons Hospice & Palliative Care of Broward, Florida

Admissions and Patient Days

First Two Years by Payer Admissions Patient Days

Payer Percent Year One Year Two Year One Year Two

Medicare 92.5% 206 374 10,933 26,179

Medicaid 3.5% 8 15 414 991

Insurance 2.5% 6 11 295 708

Charity 1.0% 3 5 118 283

Self-Pay 0.5% 2 3 59 142

TOTAL 100.0% 225 408 11,819 28,303 Source: CON application #10213, page 2-30.

(d) Projected number of admissions, by type of terminal illness, for the first two years of operation.

Compassionate Care Hospice of Broward, Inc. (CON application #10211) provided the following table

illustrating the projected number of admissions by type of terminal illness for the first two years of operation.


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Projected Number of Admissions by Diagnosis

For Compassionate Care Hospice of Broward, Inc.

Service Area 10 Disease Year One Year Two

Cancer 46 111

Cardiac 64 200

Respiratory 20 50

Renal Failure 10 40

HIV/AIDS 5 7

Other 37 36

Total 182 444 Source: CON application #10211, pages 108-109. Greystone Hospice of District 10 LLC (CON application

#10212) provided the following table illustrating the projected number of admissions by type of terminal illness

for the first two years of operation.

Projected number of Admissions by Diagnosis For Greystone Hospice

Service Area 10 Disease Year One Year Two

Cancer 40 226

Other 54 303 Source: CON application #10212, page 37.

The applicant projects to serve 266 patients in year one and

357 patients in year two.

Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON application #10213) states that terminal illnesses served will be difficult to predict, however, based

upon their affiliate’s experience in Service Area 11, they project the following admissions by disease category and age cohort:

Number of Admissions by Age and Disease Category

Seasons Hospice & Palliative Care of Broward Florida, Inc.

Years One and Two of Operations Year One Year Two

Illness 0-64 65+ Total 0-64 65+ Total

Cancer 20 52 73 37 93 130

Other 14 139 154 25 249 274

TOTAL 35 191 226 62 342 404 Source: CON application #10213, page 2-30.


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(e) Projected number of admissions, by two age groups,

under 65 and 65 or older, for the first two years of operation.

Compassionate Care Hospice of Broward, Inc. (CON application #10211) provides the following table for

the projected number of admissions by age cohort.

Projected Admissions by Age Group for Compassionate Care Hospice Florida, Inc.

Service Area 10 Under 65 Over 65 Total

Year One 18 164 182

Year Two 44 400 444 Source: CON application #10211, page 109. Greystone Hospice of District 10 LLC (CON application

#10212) provides the following table for the projected number of admissions by age cohort.

Projected Admissions by Age Group for

Greystone Hospice

Service Area 10 Under 65 Over 65 Total

Year One 82 184 266

Year Two 111 246 357 Source: CON application #10212, page 37.

Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON application #10213) includes this information in

the section (d) above.

(f) Identification of the services that will be provided directly by hospice staff and volunteers and those that will be provided through contractual arrangements.

The hospice care team shall directly provide the following

core services: nursing services, social work services, pastoral or counseling services, dietary counseling, and bereavement counseling services. Physician services may be provided by

the hospice directly or through contract. A hospice may also use contracted staff if necessary to supplement hospice employees in order to meet the needs of patients during

periods of peak patient loads or under extraordinary circumstances.


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Compassionate Care Hospice of Broward, Inc. (CON application #10211) states it will provide the core

services (physician services, nursing services, social work services, dietary counseling, pastoral and counseling

services, etc.) directly through hospice staff and volunteers. Compassionate Care states it intends to also offer non-core services that will be provided through contractual

arrangement such as: durable medical equipment, medical supplies, pharmaceuticals, physical therapy, speech and occupational therapy. Non-core services to be provided by

CCHB staff include massage therapy, music therapy, energetic care, sacred spaces, guided imagery, reminiscence

therapy, pet therapy, aroma therapy, reflexology, hypnotherapy, life enhancement services and homemaker services.

Greystone Hospice of District 10 LLC (CON application

#10212) states it will provide the core services directly by hospice staff and volunteers (nursing, social work, pastoral or counseling services, bereavement, home health aides,

homemaker and chore services). Additional services available through contractual arrangement include: medical director, alternate medical director, physical/occupational/

speech therapy, dietary/nutritional counseling, pharmacy, supplies/durable medical equipment, patient transport and

infusion therapy. Seasons Hospice & Palliative Care of Broward Florida,

Inc. (CON application #10213) states core services will be provided directly by hospice staff (nursing, social work, pastoral or counseling services, dietary and bereavement).

Core services are also described as the provision of routine, respite, inpatient and continuous care. A medical director

will be employed meeting the licensure requirements as a hospice physician. Volunteers will provide services as previously described in this report.

Additional services will be available through contractual

arrangements and include: IV therapy, physical, speech and occupational therapy, patient transport, mobile and fixed site X-ray, radiation and related oncological treatments,

nursing home and ALF patient services, laboratories, ER and outpatient hospital services and backup pharmacy/medical equipment services.

The applicant provides additional details regarding the types

of contract services available.


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(g) Proposed arrangements for providing inpatient care.

Compassionate Care Hospice of Broward, Inc.

(CON application #10211) states that inpatient care services will be provided through contractual arrangements with existing nursing homes and hospitals within HSA 10.

Compassionate Care states that it includes samples of hospital inpatient and nursing homes inpatient agreements

in its supporting documents. Supporting Documents Tab 8 of the application has a sample nursing home inpatient

agreement. The reviewer did not find a sample hospital agreement. Compassionate Care cites support letters from Florida Medical Center – A Campus of North Shore and

Plantation General Hospital, stating these show the hospitals are willing to work with Compassionate Care. These letters

do not address hospice inpatient care. Greystone Hospice of District 10 LLC (CON application

#10212) states that for the first two years of operation it expects to provide inpatient services through contractual arrangements with existing health care facilities and

includes a letter of support to this effect from Wilton Manors Health and Rehabilitation Center, a skilled nursing facility.

Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON application #10213) states that for the first two

years of operation inpatient services will be provided through contracts with hospitals and if beds are available, nursing homes. The applicant expects to actively seek contracts with

different providers, and a letter of commitment to contract for inpatient beds is included in the application (as

previously discussed) from Wilton Manors Health & Rehabilitation Center, and a letter of interest to contract from Broward Health North. The applicant includes a copy

of their “Policy Regarding Treatment of Residents in Nursing Homes” as Exhibit 2-1 (Tab 2 of CON application #10213).

(h) Proposed number of inpatient beds that will be located in

a freestanding inpatient facility, in hospitals, and in

nursing homes.

The applicants indicate that they will contract with hospitals

and nursing homes but do not provide specific numbers of inpatient beds their programs will utilize in these facilities.


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(i) Circumstances under which a patient would be admitted to an inpatient bed.

Compassionate Care Hospice of Broward, Inc.

(CON application #10211) provides a detailed list of the clinical criteria (pain and other symptoms) that should be present for the hospice patient to be considered appropriate

for admission to general inpatient care.

Compassionate Care states that it will provide respite care

when the patient’s family/caregiver needs a short period of relief. This will be offered on an “as needed” basis for a

maximum of five days per respite admission for a Medicare/Medicaid patient. For patients covered by other insurers, the duration may be approved for a longer period of

time.

Greystone Hospice of District 10 LLC (CON application #10212) references their policy regarding admissions of patients to inpatient beds, Policy #A.23.0 Inpatient Care,

which complies with Federal Medicare Guidelines for hospice inpatient care. The applicant states that patients will be admitted for management of severe symptom control, end

stage dying process or a medical crisis. The applicant states in addition to general admission criteria, inpatient

admissions will only occur during circumstances when a patient’s acute care needs cannot be adequately managed or controlled in the home setting, and includes a detailed list of

such circumstances. The applicant states if transfer occurs to inpatient settings,

ever effort will be made to provide a homelike atmosphere to the extent possible, including overnight stays from family

and by only contracting with private or semi-private rooms. Seasons Hospice & Palliative Care of Broward Florida,

Inc. (CON application #10213) states they will provide inpatient level of care for pain control, symptom

management and respite purposes for the hospice patient, and provides a detailed list of how and when this will occur.

(j) Provisions for serving persons without primary caregivers at home.

Compassionate Care of Broward, Inc. (CON application #10211) states it is committed to serving all patients

including those who do not have primary caregivers at home.


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Compassionate Care Hospice states it will admit patients to its hospice service even if the patient does not have a

caregiver at home, as evidenced by CCH’s history of serving these patient populations in its existing markets. The

applicant proposes to establish relationships with area nursing homes and assisted living facilities to appropriately serve patients in this situation, should the need arise.

Greystone Hospice of District 10 LLC (CON application #10212) states that for patients without a suitable primary

caregiver at home the applicant will seek an appropriate caregiver network among nearby relatives, friends and

neighbors; failing this, qualified sitter services may be recommended to the patient/family in order to keep the patient at home, or the patient may be placed in an inpatient

facility contracted to provide inpatient hospice care with Greystone; homeless patients may also be provided care in a

local shelter. Seasons Hospice & Palliative Care of Broward Florida,

Inc. (CON application #10213) states that a team leader will identify and direct safe and effective provision of hospice care in situations where the patient requires assistance with

self-care and skilled services, in a location that is in accordance with the patient’s wishes. Seasons states that

patients who are still able to provide their own care will be supported and managed until such time as a decline in functional ability develops with progressive disease; at this

time the interdisciplinary care team will contact friends, neighbors and community members who may function as part of the patient support network; failing this, placement

in a group home, public housing, shelter, skilled facility or general inpatient bed will be explored as potential solutions.

(k) Arrangements for the provision of bereavement services.

Compassionate Care Hospice of Broward, Inc. (CON application #10211) states its intent to provide

appropriate and coordinated bereavement services and counseling to families and caregivers for at least 13 months following the death of the patient. In addition to providing

services to family and caregivers, services may be provided to residents and staff of SNFs, ALFs and other medical facilities as needed, for at least 13 months after the patient’s death.

Bereavement services will begin with an initial bereavement risk assessment to be completed by the social worker,

bereavement coordinator or designee within five days of


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admission. A sympathy card and bereavement letter outlining the program’s bereavement services will be sent.

Within three to five weeks after the patient’s death, the bereavement follow up assessment is completed by the

bereavement counselor following the patient’s family/caregiver. The applicant states it also provides bereavement support for children, called Compassionate

Courage. The children participate in art, reading, poetry, writing exercises, group discussions, drawings, memory collages, a “feeling toss” game and books

Greystone Hospice of District 10 LLC (CON application

#10212) will provide bereavement services as part of the hospice interdisciplinary team care plan, and under the guidelines of Greystone’s policy #B-1.0, Bereavement

Program and Services. Assessment for services will begin upon admission to hospice and continue for 12 months plus

additional time accorded to individual plans of care developed for the bereaved individual. Bereavement needs are assessed throughout the time patients are receiving

hospice care. Thirteen months of supportive services are offered to surviving loved ones. The bereavement counselor will provide individualized services to grieving family

members, with the support of specially trained hospice social workers, spiritual counselors and volunteers. Support

services may include individual counseling, support groups, telephone support and written correspondence. Greystone Hospice provides bereavement services and support to the

community at large at no cost, as part of their commitment to providing support to residents within the service area.

The applicant provides additional details of the role of the bereavement counselor, support services, counseling

formats, client identification, education services, and locations for provision of these services.

Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON application #10213) views the provision of

bereavement services as a core service that must be provided. Volunteers are also trained to provide bereavement support. Seasons will provide bereavement

support to the patient and family before and following patient death in order to minimize adverse effects of the natural grief process. The applicant details bereavement

service protocols, including:


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Services will be offered for not less than 13 months

following the death of the patient, as desired by the bereaved.

Services will be goal directed, based on assessed needs,

approved by the interdisciplinary team, and will vary depending upon the degree of risk assessed. High risk

survivor follow-up will be conducted within 24 hours of patient death.

Services include calls, mailings, visits, support groups and/or referrals to community resources.

Any member of the interdisciplinary group, including trained volunteers, may delivery bereavement services;

however, overall direction will be provided by a qualified professional and all services will be documented.

Staff will receive bereavement and grief/loss education,

and Seasons Hospice will provide these services to the community and residents of the facility when appropriate,

and will host at least one memorial services per year.

(l) Proposed community education activities concerning hospice programs.

Compassionate Care Hospice of Broward, Inc. (CON application #10211) states it will provide extensive community education activities to increase hospice

awareness and utilization. Compassionate Care Hospice staffing includes 1.0 FTE professional relations coordinators

and 0.5 FTE clinical liaisons in year one increasing to 1.0 in year two of operation.

According to the applicant, these individuals will be responsible for leading the outreach for specific disease

focused programming, Jewish, Hispanic and Veterans’ outreach, and community relations development. The applicant states it will host hospice educational events at

senior organizations, religious affiliated groups, veteran’s organizations, and health fairs in an effort to educate the community at large on the benefits of holistic end-of-life care

through hospice.

Greystone Hospice of District 10 LLC (CON application #10212) will develop and implement an active community outreach and education program in Broward County, which

will include:


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A Greystone Hospice website is under development, and

will be operational prior to licensure and implementation of the proposed program, and will provide public information and prospective client materials accessible

and downloadable online.

Educational programs offering an overview of the goals,

objectives and philosophy of hospice care; programs regarding pediatric hospice care; how to cope with dying

and other outreach programs to the underserved, offered in community settings such as churches, synagogues, clubs and civic organizations.

Educational seminars presented at long term care facilities regarding care of hospice patients and

coordination between hospice care team and facility staff members.

Support groups for caregivers and family members of

terminally ill patients.

Additional presentations free to the general public on topics such as grief, dying, wills and trust, OTC

medication use and alternative care.

A training class open to the public titled “An Introduction

to Hospice”.

Public education on the many facets of death, dying, grief

and hospice care. Seasons Hospice & Palliative Care of Broward Florida,

Inc. (CON application #10213) states that a range of community education activities will occur through many venues.

Circle of Care Program will ensure widespread community

outreach via printed materials, commercials on television and radio, newspaper and magazine articles, testimonials

in person at service clubs and places of worship, schools and universities.

Partnerships with other organizations in the community

such as hospitals, nursing homes and seminars and panels sponsored by insurance companies and stock

brokers, who provide public education opportunities in which hospice team members can participate.

Hospice website and toll free number is also available to the public, and is available 24 hours a day, seven days a

week.

Management publishes education guides and brochures

which the applicant will adapt to their program.


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(m) Fundraising activities.

Compassionate Care Hospice of Broward, Inc. (CON application #10211) states that Compassionate Care

Hospice has a relationship with Compassionate Care Hospice Foundation, an unrelated not for profit 501c3 organization, whose mission is to provide the resources necessary to

support the extraordinary needs of hospice patients and their families. The applicant states that Compassionate Care Hospice does not actively raise funds from the community

but if an individual wants to make a charitable donation, Compassionate Care Hospice of Florida will direct those

individuals to Compassionate Care Hospice Foundation’s website.

Greystone Hospice of District 10 LLC (CON application #10212) has committed not to engage in fundraising

activities in the service area and conditioned their application to this effect. Persons wishing to make a donation may do so to a newly established not-for-profit

foundation, described in Condition #1 of the application (and previously discussed in this report), which will be funded by a one million dollar contribution from Greystone & Co., Inc.,

an affiliate organization, over a period of five years. The applicant will not solicit contributions, endowments, or

bequests, but will accept those which are unsolicited. Seasons Hospice & Palliative Care of Broward Florida,

Inc. (CON application #10213) states that programs and services not covered by insurance are provided to patients at Seasons Hospice, made possible by operations efficiency and

volunteers. Donations are often given without being sought; however cannot be counted upon as a steady revenue

stream. The applicant states the following regarding fundraising and donations:

Seasons Hospice Foundation is a non-profit foundation within the organization that develops community

relationships which produce and encourage donation.


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Fund-raising for hospice is sponsorship - those activities

often have a higher success rate with raising funds, and they allow the hospice to become involved with a wide range of community volunteer organizations. As an

example, asking the Alzheimer’s Association to sponsor a fund-raising event with proceeds going to hospice has

benefits for both organizations by increasing community awareness and visibility for both programs in the communities.

Fund-raising for hospice is a special day of the week - the applicant states that cities may proclaim a “hospice day”

focusing on public outreach and education, which creates opportunities for donation.

Fund-raising for hospice is partnership - activities such

as calendars featuring artwork from nursing home residents allow fund raising to occur which builds

partnerships between different community organizations.

Fund-raising for hospice is corporate - corporate gift

giving in the form of donations is growing, and gifts to hospice organizations are a well-respected fit.

Fund-raising for hospice is local and driven by appreciation - churches, temples and other religious

organizations may donate to hospice as well.

3. Statutory Review Criteria

a. Is need for the project evidenced by the availability, quality of care, accessibility and extent of utilization of existing health care facilities and health services in the applicant’s service area? ss.

408.035(1)(a) and (b), Florida Statutes.

Need for an additional hospice program is evidenced by the availability, accessibility and extent to utilization of existing health care facilities and health services in this service area. The co-batched applicants are

responding to published need of one hospice program in Hospice Service Area 10.

The following chart illustrates hospice admissions for the past five years. As shown below, admissions have overall increased from 8,228 in the 12-

month period ending June 30, 2009 to 9,102 in the 12-month period ending June 30, 2013.


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Hospice Admissions for Service Area 10 Five-Year Period Ending June 30, 2013

12 Months Ending June 30 Admissions

2013 2012 2011 2010 2009

9,102 8,748 8,574 8,295 8,228

Source: Agency for Health Care Administration Florida Need Projections for Hospice Programs, published October 2009 – 2013.

Compassionate Care Hospice of Broward, Inc. (CON application #10211) agrees with the Agency’s bed need computation as it indicates a

need for one additional hospice program in Service Area 10. The applicant states that there is a projected need for 949 additional hospice program admissions for the January 2015 planning horizon. The

applicant notes the most significant gap in services is within non-cancer cohort age 65 and older (413 hospice admissions), followed by cancer age 65 and older (249 admissions). The county in aggregate has a hospice

penetration rate of 61.5 percent, three points lower than the state average. The applicant intends to focus efforts on end-stage

cardiovascular disease residents as well as performing general hospice services for terminally-ill residents of any diagnosis.

With regard to quality of care the applicant states that its parent, Compassionate Care Hospice, is in compliance with the conditions of

participation for hospice providers of services under the Health Insurance for the Aged and Disabled program (Title XVIII of the Social Security Act) as well as the Medicaid program, and has never had any

Medicare cap issues or other investigations or focused reviews. An extensive discussion of quality of care is provided in response to question 4(b) below.

The applicant states it will provide all required core components of

hospice care set forth by Medicare Conditions of Participation as well as Florida Hospice licensure requirements as discussed previously in this report, and conditions approval of CON #10211 on numerous quality of

care enhancement activities.

The applicant also states its parent company, CCH, has been operating hospice programs for 19 years and is familiar with the many procedures that enhance efficiency in the provision of quality hospice care. A copy of

the CCH Policies and Procedures manual highlights is included in the Supporting Documents of the application.

CCHB states intent to admit all patients without regard to payment just as its sister programs do throughout the country.


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Greystone Hospice of District 10 LLC (CON application #10212) undertook its own needs assessment in order to conclude there are no

populations within Service Area 10 whose needs are completely unmet; however, the applicant anticipates population growth and increasing

cultural diversity necessitate hospice services sensitive to the specific populations in Broward County, such as the Hispanic, Jewish and Haitian communities.

As previously stated, Greystone Hospice is committed to providing hospice care oriented to the distinct language, cultural and religious

beliefs of these groups, both now and as service demands increase with population growth. The applicant estimates first and second year

admissions of the proposed project to be 266 and 357 respectively, a market share of just 2.6 percent, which will pose no adverse impact to existing providers, while allowing Greystone to build a viable program.

Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON

application #10213) notes that volunteers, through their hospice involvement and advocacy within the community, play a vital role making quality hospice care available and accessible. A summary of the

applicant’s response to the review criteria is shown below: Availability

The applicant states that the ability of hospice programs to expand

availability is based upon how many staff can be employed and how efficiently the program operates.

Seasons Hospice submits the following table to show that of the six hospice providers currently in Hospice Service Area 10, one (VITAS) controls 79 percent of market share, while five hospices share the

remaining 21 percent of the hospice market:

Hospice

Total Patient

Days (CY 2012)

Percent Patient

Days (CY 2012) Catholic Hospice 31,454 4.44%

Heartland Hospice 418 .06%

Hospice by the Sea 93,180 13.15%

Hospice of the Gold Coast 12,660 1.79%

Hospice of PBC 10,558 1.49%

VITAS 560,472 79.08%

Broward Total 708,742 100.01%* Source: CON application #10213, page 3-2. Note: *The applicant states the total as 100% probably due to rounding. Patient days provided for hospices

serving multiple service areas are based on the applicant’s weighting service area admissions reported to the Agency and patient days reported to DOEA.


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As previously discussed, the applicant cites Seasons Hospice District 11 experience with the former Douglas Gardens Hospice to show that

Seasons Hospice is responsible for 62 percent of the growth in the District 11 market over a period of three years, proving ability to improve

access and availability. The applicant submits the following chart demonstrating Seasons

hospice market share in District 11 during CY 2012:

Hospice Service Area 11

Calendar Year 2012

Patient Days

Hospice

Total Patient Days

Percent of Patient Days

Catholic Hospice 158,727 16.4%

Heartland Hospice 249 0.03%

Heartland Hospice f/k/a Hospice of SE Florida 366 0.04%

Hospice Care of South Florida 22,972 2.4%

Hospice of the Florida Keys 11,981 1.2%

Odyssey Healthcare 96,817 10.0%

Seasons Hospice 96,152 10.0%

Vitas Healthcare Corporation of Florida 577,964 59.9%

Service Area 11 Total 965,228 100.0% Source: CON application #10213, page 3-3.

The applicant notes the above chart demonstrates Seasons Hospice ability to capture market share on par with other top providers of hospice care in District 11, within just three years of assuming operations in the

area. Quality of Care

As stated previously, the applicant will ensure quality of care through the

following measures:

Accreditation by the Joint Commission

Oversight by integration with affiliated hospices

NHPCO and FHPO membership

NHPCO’s Quality Partner performance Improvement Plan

participation

National Ethics Committee involvement

Internal quality improvement

Participation in the Agency Family Evaluation of Hospice Care Survey

Partnership with local and state colleges regarding end-of-life research

efforts.

Additionally, the applicant reviews the company code of conduct, and core philosophy that emphasized dignity in the treatment of employees and patients.


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Access

The applicant states that although state law prevents hospice

discrimination based on patient ability to pay, and there are no existing geographic access problems in District 10, despite it being the second largest service area in terms of population, it ranks 25th out of 27 service

areas in terms of having the highest unmet need for hospice service. Access will be improved per the applicant by ensuring that information

about hospice services are made available to the “gatekeepers” who assist patients making health care decisions, such as doctors, religious leaders,

social workers, schools, hospitals and nursing homes. The applicant will focus on outreach to these organizations, a process which has shown success in other Seasons hospice programs and which has already

begun in District 10 (as previously discussed in letters of support), and is further evidenced by the condition to provide CEUs and internship

opportunities to the health care community. Extent Of Utilization

The applicant states that low hospice penetration rates are problematic for Broward County: for the 12-month period ending June 30, 2013,

District 10 ranks 24th out of 27 hospice areas, the fourth lowest hospice penetration rate at 62.3 percent, compared to the state average of 68

percent. The applicant notes that the gap in hospice admissions in this area has only widened since 2006 when the Agency published need for another program. Although Catholic Hospice was approved in 2006, and

Hospice of Palm Beach County was approved in 2010, the need for hospice care persists in District 10.

The applicant notes that for the same twelve month period ending June 30, 2013, the combined admissions for Catholic Hospice and Hospice of

Palm Beach County totaled 786, reducing the net need to 949 for the current batching cycle; existing and new programs have not grown sufficiently to meet the demands of population growth in the area.

Seasons Hospice identifies the underserved groups of this population based on cultural, racial and diagnosis categories, and states they have

the programs, services, community outreach and proven success in adjacent Service Area 11 to improve access and utilization of hospice services in Broward County.


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b. Does the applicant have a history of providing quality of care? Has

the applicant demonstrated the ability to provide quality care? ss. 408.035(1), (c), Florida Statutes.

Compassionate Care Hospice of Broward, Inc. (CON application #10211) is a shell entity formed for the purpose of establishing hospice

services in Broward County and therefore has no operational history. However, CCHB’s parent, Compassionate Care Group, Ltd. has been providing hospice care since 1993 and has initiated a program in

Subdistrict 6B (Polk, Highlands and Hardee Counties). Compassionate Care has 35 hospice programs and approximately 55 office locations in

22 states. The Subdistrict 6B program, licensed in February 2011, has an ADC of 100 patients, and CCH has an additional two programs approved in Florida. As previously noted, Compassionate Care’s Service

Area 11 hospice program was licensed effective January 13, 2014.

The applicant states that existing CCH operations have no licensure violations or Medicare cap issues, and that CCH is a member of the National Hospice and Palliative Care Organization (NHPCO). The

application includes highlights from the CCH hospice program operating policies and procedures manual, which will be reviewed and revised if necessary to ensure compliance with all details of Florida licensure

before being implemented by the applicant.

Additional quality measures include:

Community Health Accreditation Program, Inc. (CHAP)-all CCH

existing hospice operations are either currently or in the process of obtaining CHAP accreditation. CHAP is an independent, not for profit

accrediting body for community health programs and is a leader in improving the quality of community based healthcare services.

CCH surpasses NHPCO standard staffing ratios and guidelines that are direct patient care roles.

CCHB will comply with the company wide CCH Quality Assessment and Performance Improvement Plan (QAPI), a data driven program

that focuses on indicators related to improved palliative outcomes, end of life support and demonstrates improvement in hospice performance.

CCH has a contractual arrangement with OCS Home Care, a consulting firm that delivers business intelligence to home health and

hospice providers, through comparative benchmarks with other hospice programs of similar size. Areas of improvement and excellence are identified and shared with staff to ensure continuous

improvement in challenging areas.

Patient/Family Satisfaction Surveys


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Continuing Education, In Service Training and Memberships in

Quality Associations

Quality Conditions of the Application

Agency records indicate that Compassionate Care Hospice had one substantiated complaint for the three-year period ending

December 13, 2013 in the following category: resident/patient/client rights.

Compassionate Care Hospice did not participate in the Agency’s most recent (January-March 2013) Hospice Provider Family Satisfaction

Survey.17 Compassionate Care Hospice did participate in the statewide

patient/family satisfaction survey for CY 2012, complied by the Department of Elder Affairs (DOEA). The survey results are indicated as percentages for three Outcome Measures—1, 2 and 2A.

Outcome Measure 1 measures the percentage of patients who had severe

pain (seven or higher on the 0-to-10 scale) at admission and whose pain was reduced to a level of five or less by the end of the fourth day of care

in the hospice program. Outcome Measure 2 includes the following question: Did the patient

receive the right amount of medicine for his or her pain? Outcome Measure 2A includes the following question: Based on the care

the patient received, would the patient and/or responsible party recommend hospice services to others?

Per the DOEA’s 2013 Report on Hospice Demographic and Outcomes Measures, issued October 2013 (for calendar year 2012), family and

patient satisfaction survey results on Compassionate Care Hospice’s performance, existing Hospice Service Areas 6B, 10 and the state average

are shown below.

17 Per the Agency website at http://www.floridahealthfinder.gov/Hospice/CompareHospiceStats.aspx.

http://www.floridahealthfinder.gov/Hospice/CompareHospiceStats.aspx


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Florida Department of Elder Affairs

CY 2012 Report on Hospice Demographics & Outcome Measures

Hospice Service Areas 6B and 10 & State Average Outcome Measure

Hospice

1

2

2A

Number of Patients

Compassionate Care Hospice of Miami-Dade, Inc. 75% 85% 96% 301

Cornerstone Hospice & Palliative Care 84% 95% 92% 4,481

Good Shepherd Hospice 97% 95% 97% 3,430

Catholic Hospice, Inc. 93% 97% 88% 2,399

Heartland Hospice Services f/k/a Hospice SE Florida 88% 100% 93% 784

Hospice By The Sea, Inc. 88% 93% 95% 3,716

Hospice of Gold Coast Home Health Services 91% 99% 99% 437

Hospice of Palm Beach County, Inc. 83% 96% 99% 6,701

Vitas Healthcare Corp. (Boynton Beach) 86% 94% 96% 7,335

State 84% 95% 97% 116,242 Source: DOEA, 2013 Report on Hospice Demographics and Outcomes Measures, issued October 2013 for

calendar year 2012, pages 8-10. Note: Florida hospices reported pain level data for 53,097 patients at the time of admission and 8,966 patients reported severe pain on admission. There were 18,958 survey responses to Outcome Measure 2 and

25,489 responses to Outcome Measure 2A. Number of responses by hospice was not provided.

As shown in the table above, Compassionate Care Hospice’s

patient/family satisfaction is at 75.0 percent for Outcome Measure 1, 85.0 percent for Outcome Measure 2 and 96.0 percent for Outcome Measure 2A. This is lower than the state average in all Outcome

Measures. Compassionate Care is also lower than every Service Area 6B and 10 provider in Outcome Measures 1 and 2. Compassionate exceeds four providers on Measure 2A and is tied for fourth highest with Vitas

Healthcare Corp.

Greystone Hospice of District 10 LLC (CON application #10212) is a newly-formed development stage corporation and as such does not have a licensure history or accreditations. However, the applicant refers to

sister company Greystone HCM, a provider of skilled nursing, assisted living and home health care through licensed facilities in Florida and

other states since 2001. The applicant discusses Greystone HCM’s quality of care model applicable to the proposed hospice program, including:

Greystone Healthcare Managements Provision of Care

Key principles of Greystone HCM management, Greystone HCM clinical operations and community relations are also detailed.

Greystone HCM Five Stages of Quality Assurance/Performance Improvement (QAPI)


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Applicant’s Ability to Provide Quality Care-the applicant notes that

Greystone HCM owns the Broward County facility Wilton Manors. This gives the applicant insight into the needs of health care providers in this area, and provides a connection for oversight and expertise in

development and implementation of the proposed program. Greystone Hospice reviews six of the key executive staff personnel

who will participate in this capacity with the applicant, and has developed its own Policies and Procedures Operating Manual for hospice, and detailed job descriptions for hospice staff and volunteers

(Volume 2, Tab 6).

Quality Assessment and Performance Improvement Program (QAPI)-

the applicant evaluates all levels of care, including routine home care, inpatient, continuous home care and respite services, as well as overall organization, in order to guarantee the proposed program

functions according to the mission and goals of the organization. o Quality Assessment Committee-Quality Assessment is overseen by

an administrator, who is assisted by a committee that meets at least four times annually. The committee utilizes Quality Assessment processes in order to ensure that the program’s quality

of care is assessed and maintained, that patient access to care is periodically reviewed and performance is improved.

o QAPI Program-the applicant provides a detailed overview of the indicators and measures used to determine actual or potential problems, as well as steps taken when problems are identified,

including: Reporting and Making Recommendations to the Governing Body, Performance Improvement Teams and Guidelines for Performance Improvement Teams.

The applicant states it will develop and implement a comprehensive emergency management plan for Broward County upon approval of

the proposed project.

Greystone Hospice states it will collect data and information for both

internal analysis and regulatory reporting, and will comply with all Agency and other government oversight requirements. The applicant

has conditioned approval of the project on the voluntary reporting to the Agency “Family Evaluation of Hospice Care (FEHC) Satisfaction Survey” found at FloridaHealthFinder.gov, to be measured by

submission of the requested information.

Agency licensure records indicate during the three-year period ending on December 6, 2013. The 18 Greystone Healthcare Management Corporation affiliated skilling nursing homes in Florida (2,106 beds) had

64 substantiated complaints. A single complaint can encompass multiple complaint categories. The table below has these listed by complaint categories.


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Greystone Healthcare Management Corporation Affiliated Nursing Homes

Substantiated Complaint Categories for the 36 Months Ending

December 6, 2013 Complaint Category Number Substantiated

Quality of Care/Treatment 37

Resident/Patient/Client Assessment 9

Administration/Personnel 8

Admission, Transfer & Discharge Rights 6

Physical Environment 6

Resident/Patient/Client Rights 5

Dietary Services 4

Nursing Services 4

Infection Control 3

Falsification of Records/Reports 2

Physician Services 2

Resident/Patient/Client Abuse 1

Unqualified Personnel 1 Source: Agency for Health Care Administration complaint records.

Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON application #10213) is a newly formed entity created for the purpose of

establishing a hospice program in Service Area 10, Broward County. As such, it does not have a historical provision of quality of care. However,

ownership of the applicant is the same as that for Seasons Hospice & Palliative Care of Southern Florida, Inc. (Hospice Service Area 11) and 20 percent of shares issued for the applicant are owned by Miami Jewish

Health Systems; because the remainder of the ownership is comprised of the same persons in both hospice corporations, the applicant states this

ensures continuity in mission, vision and values. Per the applicant, Seasons Healthcare Management provides

management services to both the new District 10 and existing District 11 Seasons Hospice programs; with the same company providing daily operation control uniformity both locally as well as nationally, as this

company also serves other Seasons hospice affiliates. The applicant includes supplemental information regarding management personnel in

Tab 5 of the application. The applicant provides a list of the 17 Seasons Hospice & Palliative Care

programs that have received The Joint Commission Gold Seal of Approval accreditation for their home care programs (Exhibit 4-1), and states

intent to seek the same for the new program. Seasons Hospice states quality is achieved through competency and

education; as previously discussed, the applicant will provide both CEUs and internship opportunities to health care professionals in Broward County, and has conditioned the application to this effect (Exhibit 4-2

includes a copy of Seasons Certificate of Accreditation to provide accreditation opportunities; Exhibit 4-3 includes sample internship

notices for Seasons Hospice of Miami which describe the internship program).


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Additional quality measures discussed include Seasons Hospice

involvement in national research initiatives and their Compassionate Allies Program, which provides on going hospice experience for nurses

and medical students. Seasons also ensures quality of care through:

Electronic Medical Records-this provides statistical data, integration

of medication tracking, patient status updates available at all hours of the day to employees on shift

Electronic Call Center-integrated into the EMR, coverage is available 24 hours a day, seven days a week, staffed by Seasons employees.

Ongoing Competency Assessment of Patient Care Staff

Specialized Programs: Music Therapy, Leaving A Legacy, A Touch for

All Seasons Dementia Program, Massage Therapy, Volunteer Vigil, Spiritual Presence , Loyal Friends Pet Team, Music Companion

CareFlash-online care support community

Open Access Services

We Honor Veterans Program

Camp Kangaroo

Kavod haNe-fesh Jewish hospice program

Friendly Visitor Bereavement Program

The applicant provides a detailed discussion of their Quality Assurance and Performance Improvement Program (QAPI), which utilizes data to

assess outcomes. The applicant provides an overview of their plan for monitoring the

allocation and utilization of patient and family services, as well as their participation in identifying, reporting, analyzing and managing sentinel

events (an unexpected occurrence involving death or serious physical/psychological injury) in order to prevent such incidents and improve patient care.

Seasons Hospice & Palliative Care states their current CEO serves on the

Public Policy Board for the National Hospice and Palliative Care Organization (of which Seasons Hospice is also a member); Seasons is also a member of the Florida Hospices and Palliative Care organization.

The applicant reviews the ten components of hospice care identified by NHPCO, and lists six performance measures and reports with which Seasons Hospice participates.

Additionally, the applicant reviews the NHPCO keys to quality care which

Seasons integrates into their hospice programs. These keys include planning and information; recognizing that hospice care is increasingly


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what Americans, with an aging population, want, and need more information about end-of-life care; hospice is the model for end-of-life

care; and hospice as the gold standard for end-of-life care.

During the 36-month period ending December 13, 2013, Seasons Hospice had no substantiated complaints.

Seasons Hospice & Palliative Care of Southern Florida, Inc. participated in the Agency’s Hospice Provider Family Satisfaction Survey. The most recent results of this survey range from January 2013 through March

2013. Per the Agency website at http://www.floridahealthfinder.gov/Hospice/CompareHospiceStats.aspx,

Seasons attained a five-star rating in three and a four-star rating in two of the five questions in the survey. Respondents ranged from a low of 12 to a high of 17. The five-star rating is the highest attainable and

indicates respondents were 90 to 100 percent satisfied with the hospice’s performance. The four star rating indicates that 80 to 89 percent of the

respondents were satisfied with the hospice’s performance.

Florida Department of Elder Affairs

CY 2012 Report on Hospice Demographics & Outcome Measures

Hospice Service Areas 11 and 10 & State Average Outcome Measure

Hospice

1

2

2A

Number of Patients

Seasons Hospice & Palliative Care of Southern Florida 94% 90% 100% 912

Hospice Care of South Florida 100% 100% 100% 101

Gentiva Hospice f/k/a Odyssey 91% 93% 92% 1,333

Heartland Hospice Services 86% 96% 97% 230

Hospice of the Florida Keys 94% 96% 100% 216

Vitas Healthcare Corp. (North Miami Beach) 85% 94% 96% 6,787

Catholic Hospice, Inc. (SA 11 & 10)* 93% 97% 88% 2,399

Heartland Hospice Services f/k/a Hospice SE Florida* 88% 100% 93% 784

Hospice By The Sea, Inc. 88% 93% 95% 3,716

Hospice of Gold Coast Home Health Services 91% 99% 99% 437

Hospice of Palm Beach County, Inc. 83% 96% 99% 6,701

Vitas Healthcare Corp. (Boynton Beach) 86% 94% 96% 7,335

State 84% 95% 97% 116,242 Source: DOEA, 2013 Report on Hospice Demographics and Outcomes Measures, issued October 2013 for calendar year 2012, pages 8-10.

Note: Florida hospices reported pain level data for 53,097 patients at the time of admission and 8,966 patients reported severe pain on admission. There were 18,958 survey responses to Outcome Measure 2 and 25,489 responses to Outcome Measure 2A. Number of responses by hospice was not provided.

As shown in the table above, Seasons Hospice & Palliative Care of Southern Florida’s patient/family satisfaction is at 94 percent for Outcome Measure 1, 90 percent for Outcome Measure 2 and 100 percent

for Outcome Measure 2A. Seasons is higher than the state average in two Outcome Measures and lower at 90 percent compared to the state’s

95 percent in Outcome Measure 2. Seasons at 100 percent in Outcome Measure 2A exceeds all Service Area 10 providers and is tied with two other Service Area 11 providers. Seasons’ is lower than every Service

http://www.floridahealthfinder.gov/Hospice/CompareHospiceStats.aspx


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Area 11 and 10 provider in Outcome Measure 2. Seasons 94 percent in Outcome Measure 1 exceeds all SA 10 providers and is tied for second

with Hospice of the Florida Keys (SA 11). Hospice Care of South Florida (SA 11) at 100 percent is the highest in this measure.

Seasons Hospice & Palliative Care of Southern Florida’s patient/family satisfaction at 94 percent for Outcome Measure 1, 90 percent for

Outcome Measure 2 and 100 percent for Outcome Measure 2A exceeds Compassionate Care Hospice’s patient/family satisfaction of 75 percent for Outcome Measure 1, 85 percent for Outcome Measure 2 and 96

percent for Outcome Measure 2A.

c. What resources, including health manpower, management personnel, and funds for capital and operating expenditures, are available for project accomplishment and operation?

ss. 408.035(1)(d), Florida Statutes.

Compassionate Care Hospice of Broward, Inc. (CON application #10211): The audited financial statements of the applicant were reviewed to assess the financial position as of the balance sheet date and

the financial strength of its operations for the period presented. The applicant is a Florida for-profit corporation and a development stage

company that was formed on October 11, 2013 for the purpose of operating a hospice in Florida, with net assets of $10,000 and no

liabilities for the period ended December 9, 2013. As of the date of the audit, no operating results were available. Without results from operations, an analysis of the short and long-term strength of the

applicant cannot be made. Capital Requirements:

Schedule 2 indicates total capital projects of $142,965 which is the CON subject to this review and capital expenditures. In addition, the

applicant will have to fund the projected year one operating loss of $215,104.

Available Capital: The applicant provided a letter from Compassionate Care Group, Ltd

(Parent) which states the parent will provide funding for the project. The applicant states that the parent’s December 31, 2012 financial statements show $9.7 million available for taxes and investments.

However, no audited financial statements of the parent were provided, only an unaudited profit and loss statement. The letter also states that the parent has a $2,000,000 revolving line of credit. The parent did not

provide a statement from any bank indicating the current available


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balance in the revolving line of credit. Without a current available balance for the line of credit and/or current audited financial

statements, we cannot rely on the information presented in the application that would support the parent’s ability to fund the project.

Conclusion: Funding for this project is in question.

Greystone Hospice of District 10 LLC (CON application #10212): The audited financial statements of the applicant were reviewed to assess the financial position as of the balance sheet date and the financial strength

of its operations for the period presented.

The applicant, a Florida developmental stage corporation, provided audited financial statements for the period ending December 31, 2012 of their parent company. These statements were analyzed for the purpose

of evaluating the applicant’s ability to provide the capital and operational funding necessary to implement the project.

Short-Term Position: The balance sheet does not indicate what items are current and which

are long-term. Because of this, the Agency cannot determine the position of the applicant for measurements that require current assets or liabilities for their calculation. The parent had a negative cash flow from

operations from the most recent year of operations. Based on the limited data provided by the applicant it appears that the applicant has a weak

short-term position (see Table 1). Long-Term Position:

The balance sheet does not indicate what items are current and which are long-term. Because of this, the Agency cannot determine the position of the applicant for measurements that require long-term assets or

liabilities for their calculation. The ratio of net assets to total assets of 0.16 is below average, a weak position. The ratio of cash flow to total

assets of negative 17.4 percent is below average and a weak position. The most recent year had an operating gain of $46.6 million, which resulted in a 21 percent operating margin. Overall, the applicant has a

moderately weak long-term position (see Table 1).

Capital Requirements: Schedule 2 indicates total capital projects of $387,454 which consist of the CON subject to this review and estimated capital expenditures in

year two.


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Available Capital: Funding for this project will be provided by the applicant’s parent. The

applicant has cash and cash equivalents of $23.8 million. The applicant appears to have sufficient capital to fund this project and the entire

capital budget. Conclusion: Funding for this project should be available as needed.

TABLE 1 Greystone Hospice of District 10 LLC

CON application #10212

12/31/2012

Current Assets (CA) $0

Cash and Current Investment $23,879,897

Total Assets (TA) $998,703,704

Current Liabilities (CL) $0

Total Liabilities (TL) $834,754,312

Net Assets (NA) $163,949,392

Total Revenues (TR) $221,720,883

Interest Expense (IE) $18,521,581

Operating Income (OI) $46,598,448

Cash Flow from Operations (CFO) ($173,549,452)

Working Capital $0

FINANCIAL RATIOS

12/31/2012

Current Ratio (CA/CL) N/A

Cash Flow to Current Liabilities (CFO/CL) N/A

Long-Term Debt to Net Assets (TL-CL/NA) N/A

Times Interest Earned (OI+IE/IE) 3.5

Net Assets to Total Assets (NA/TA) 16.4%

Operating Margin (OI/TR) 21.0%

Return on Assets (OI/TA) 4.7%

Operating Cash Flow to Assets (CFO/TA) -17.4%

Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON application #10213): The audited financial statements of the applicant were reviewed to assess the financial position as of the balance sheet

date and the financial strength of its operations for the period presented.

The applicant is a Florida corporation and a development stage company that was formed on October 4, 2013 for the purpose of operating a hospice in Florida, with total assets of $1,500,000 and liabilities of

$20,500 for the period ended November 30, 2013. As of the date of the audit, no operating results were available. Without results from

operations, a complete analysis of the short and long-term strength of the applicant cannot be made.


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Short-Term Position: The applicant’s current ratio of 73.2 indicates current assets are over

73.2 times greater than current obligations. This is above average, a strong position. The applicant has working capital of $1,479,500.

Overall, the applicant has a strong short-term position (see Table 1). Long-Term Position:

The ratio of long-term debt to net assets of 0.0 indicates the applicant has no long-term debt, a strong position. Overall, the applicant has a strong long-term position (see Table 1).

Capital Requirements:

Schedule 2 indicates total capital projects of $592,610 which consist of the CON subject to this review. In addition, the applicant will have to fund the projected year one loss of $390,700.

Available Capital:

Funding for this project will be provided by the applicant. Based on our review, the applicant has cash of $1,500,000. The applicant appears to have sufficient capital to fund this project.

Conclusion: Funding for this project should be available as needed.

TABLE 1 Seasons Hospice & Palliative Care of Broward Florida, Inc.

CON application #10213

11/30/2013

Current Assets (CA) $1,500,000

Cash and Current Investment $1,500,000

Total Assets (TA) $1,500,000

Current Liabilities (CL) $20,500

Total Liabilities (TL) $20,500

Net Assets (NA) $1,479,500

Total Revenues (TR) $0

Interest Expense (IE) $0

Operating Income (OI) $0

Cash Flow from Operations (CFO) $0

Working Capital $1,479,500

FINANCIAL RATIOS

11/30/2013

Current Ratio (CA/CL) 73.2

Cash Flow to Current Liabilities (CFO/CL) 0.0

Long-Term Debt to Net Assets (TL-CL/NA) 0.0

Times Interest Earned (OI+IE/IE) N/A

Net Assets to Total Assets (NA/TA) 98.6%

Operating Margin (OI/TR) N/A

Return on Assets (OI/TA) 0.0%

Operating Cash Flow to Assets (CFO/TA) 0.0%


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d. Will the proposed project foster competition to promote quality and cost-effectiveness? ss. 408.035(1) (e) and (g), Florida Statutes.

The following applies to all applicants.

This application is for a new hospice agency to be located in Service Area 10 which currently has six existing hospice programs. Therefore, this

project is offering a new choice of provider in the service area. The impact of the price of services on consumer choice is limited to the

payer type. Most consumers do not pay directly for hospice services rather they are covered by a third-party payer. The impact of price

competition would be limited to third-party payers that negotiate price for services, namely managed care organizations. Therefore, price competition is limited to the share of patient days that

are under managed care plans.

Compassionate Care Hospice of Broward, Inc. (CON application #10211) is projecting 1.6 percent of its patient days from managed care/commercial insurance payers, 97.1 percent from fixed price

government payer sources (Medicare and Medicaid), and 1.3 percent as self-pay/charity.

Greystone Hospice of District 10, LLC (CON application #10212) is projecting 3.0 percent of its patient days from managed care/commercial

insurance payers and charity care and 97.0 percent from fixed price government payer sources (Medicare and Medicaid).

Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON application #10213) is projecting 2.5 percent of its patient days from managed care/commercial insurance payers, 96.0 percent from fixed

price government payer sources (Medicare and Medicaid) and 1.5 percent as self-pay/charity.

With the large majority of patient care being provided from fixed price government payer sources, this project is not likely to have any

discernable positive impact on price-based competition to promote cost-effectiveness. As providers offer new or enhanced services to patients

and families as a means to compete on quality measures, cost-effectiveness would be impacted since the new or enhanced services would be offered despite the large percentage of fixed priced government

payers. In other words, the potential exists for new or enhanced services to be provided for the same federal and state dollars.

Conclusion: The project is not likely to result in price-based competition.


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e. What is the immediate and long-term financial feasibility of the proposal? ss. 408.035 (1)(f), Florida Statutes.

The following applies to all applicants:

The applicant indicated on Schedule 7 that the service it intends to provide is routine home care, continuous home care, respite, and general

inpatient care, for which the Department of Health and Human Services sets rates. The federal rates were calculated for the Broward County, Florida Wage Index for Medicare Hospice payments of 1.0160 and

inflated through December 2016. The average price adjustment factor used was 2.71 percent per year based on the new CMS Market Basket

Price Index, as published in The 3rd Quarter 2013 Health Care Cost Review.

Estimated patient days for each level of service from Schedule 7, year two were multiplied by the calculated reimbursement rate for that service in

order to estimate the total revenue that would be generated by that number of patient days. The results were then compared to the applicant’s estimated gross revenue and the results of the calculations

are summarized in the Hospice Revenue Table(s) below for Compassionate Care Hospice of Broward, Inc. (CON application #10211)

and Greystone Hospice of District 10, LLC. (CON application #10212). Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON application #10213) did not provide information detailing the patient

days per service.

The applicants offered several conditions to their proposed hospice programs. None of the conditions appear to have a material financial impact to the projections.

Compassionate Care Hospice of Broward, Inc. (CON application #10211): For year two of operations, the applicant projected the

following percentage of total patient days by group: Medicare at 94.1 percent, Medicaid at 3.0 percent, self-pay/charity at 1.3 percent, and

commercial insurance and other payers at 1.6 percent.

The applicant’s projected gross revenue was 1.6 percent, or $71,705, less

than the calculated gross revenue. Operating profits from this project are expected to increase from an operating loss of $215,104 for year one

to an operating profit of $729,076 for year two. Conclusion: Assuming the applicant can obtain the necessary

financing; this project appears to be financially feasible.


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HOSPICE REVENUE TABLE

CON application #10211 Compassionate Care Hospice of Broward

Wage Index for Broward County(1.0160)

Wage Component

Wage Index

Adjusted Wage

Amount Unadjusted Component

Payment Rate

Routine Home Care $107.37 1.016 $109.09 $48.89 $157.98 Continuous Home Care $626.05 1.016 $636.07 $285.09 $921.16 Inpatient Respite $91.98 1.016 $93.45 $77.94 $171.39 General Inpatient $444.35 1.016 $451.46 $249.84 $701.30

Payment Rate

Inflation Factor Year Two

Inflation Adjusted Amount

Patient Days Year 2, December 31 -2016

Calculated Gross

Revenue Routine Home Care $157.98 1.061 $167.62 23,320 $3,908,983 Continuous Home Care $921.16 1.061 $977.40 359 $350,887 Inpatient Respite $171.39 1.061 $181.86 24 $4,365 General Inpatient $701.30 1.061 $744.12 239 $177,844

Total 23,942 $4,442,079

From Schedule 7 $4,370,374

Difference

-$71,705

Percentage difference -1.64%

Greystone Hospice of District 10 LLC (CON application #10212): For

year two of operations, the applicant projected the following percentage of total patient days by group: Medicare at 93.1 percent, Medicaid at 3.9

percent, and commercial insurance and other payers at 3.0 percent.

The applicant’s projected gross revenue was 8.49 percent, or $411,974,

less than the calculated gross revenue. Operating profits from this project are expected to increase from negative $268,691 for year one to

$327,135 for year two. Conclusion: This project appears to be financially feasible.


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HOSPICE REVENUE TABLE

CON application #10212 Greystone Hospice of District 10, LLC Wage Index for Broward County(1.0160)

Wage Component

Wage Index

Adjusted

Wage Amount

Unadjusted Component

Payment Rate

Routine Home Care $107.37 1.016 $109.09 $48.89 $157.98 Continuous Home Care $626.05 1.016 $636.07 $285.09 $921.16 Inpatient Respite $91.98 1.016 $93.45 $77.94 $171.39 General Inpatient $444.35 1.016 $451.46 $249.84 $701.30

Payment Rate

Inflation Factor

Year Two

Inflation Adjusted Amount

Patient Days

Year 2, December 31 -2016

Calculated Gross

Revenue Routine Home Care $157.98 1.061 $167.62 20,721 $3,473,329 Continuou

s Home Care $921.16 1.061 $977.40 1,181 $1,154,310 Inpatient Respite $171.39 1.061 $181.86 52 $9,457 General Inpatient $701.30 1.061 $744.12 844 $628,037

Total 22,798 $5,265,132

From Schedule 7 $4,853,158

Difference

-$411,974

Percentage difference -8.49%

Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON

application #10213): For year two of operations, the applicant projected the following percentage of total patient days by group: Medicare at 92.5 percent, Medicaid at 3.5 percent, self-pay at 0.5

percent, charity at 1.0 percent, and commercial insurance at 2.5 percent.

As previously stated, the applicant failed to provide information detailing the patient days per service. The Agency uses this information to re-calculate the expected revenues to determine if the revenue projected by

the applicant is reasonable. Without this information, the Agency cannot form an opinion on the reasonableness of the projected revenues. However, the applicant provided an independent accountants report from

Moore Stephens Lovelace, P.A., which stated “the accompanying financial forecast indicates that sufficient revenues could be generated to meet the

Hospice’s annual operating expenses during the forecast period.”18 Conclusion: This project appears to be financially feasible.

18 Moore Stephens Lovelace, P.A., report dated December 16, 2013.


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f. Are the proposed costs and methods of construction reasonable? Do they comply with statutory and rule requirements?

ss. 408.035(1)(h), Florida Statutes.

Each of the co-batched applicants is requesting approval to establish a new hospice program. There are no construction costs and methods associated with the proposals.

g. Does the applicant have a history of providing health services to

Medicaid patients and the medically indigent? Does the applicant

propose to provide health services to Medicaid patients and the medically indigent? ss. 408.035(1)(i), Florida Statutes.

Compassionate Care Hospice of Broward, Inc. (CON application #10211) states that its parent company Compassionate Care Group, Ltd,

through its other Compassionate Care Hospice subsidiaries has a history of providing health services to Medicaid patients and the medically

indigent. Schedule 7A shows 1.3 percent of total annual patient days for charity

care in years one and two of operations. Compassionate Care’s patient day Medicaid percentage is projected to be 3.0 percent for years one and two of operations.

Greystone Hospice of District 10 LLC (CON application #10212) is a

newly formed entity and does not have any operational history. However, the applicant states intent to provide care to all patients in the service area, regardless of ability to pay. The applicant notes that it conditions

approval of the project on the establishment of a new non-profit charitable foundation, funded through one million dollars in contributions from Greystone & Co., Inc. during the initial five-year

period of hospice program licensure, with at least $200,000 contributed within 90 days of initial licensure of the proposed hospice program, and

will distribute funds based on local needs as demonstrated through registered not-for-profit organizations work in the community.

Schedule 7A shows Greystone Hospice of District 10 LLC’s patient days by payor as follows: 3.9 percent Medicaid patient days for years one and

two of operations, and one percent self-pay for the first two years of the project.

Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON application #10213) is a development stage corporation with no operational history. However, the applicant reviews the provision of care

by the Seasons Hospice affiliate in Hospice District 11. Per the applicant, during 2012, Seasons Hospice provided 7.6 percent combined

patient days to Medicaid and uncompensated care in District 11. By


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comparison, the applicant notes that during the same year the District 10 combined average was only 4.9 percent, and the competing applicant

Compassionate Care Hospice reported four percent combined Medicaid and uncompensated care during 2012.

The applicant’s Schedule 7A forecasts 3.5 percent Medicaid patient days in year one and two of operations, and a combined 1.5 percent self-

pay/other patient days for the first two years of the project.

F. SUMMARY

A fixed need pool was published for a new hospice program in Hospice Service Area 10, Broward County. The applicants’ projects are in response to published need.


#10211) proposes total project costs of $142,965 with year one operating costs of $1,559,157 and year two costs of $3,586,231.

Compassionate Care proposes 10 conditions. See pages 11-13 for an in-depth description of the applicant’s proposed conditions.

Greystone Hospice of District 10 LLC (CON application #10212) proposes total project costs of $337,064 with year one operating costs of

$2,770,938 and year two costs of $4,727,017. Greystone Hospice proposed five conditions. See pages 14 and 15 for an

in-depth description of these proposed conditions. Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON

application #10213) proposes total project costs of $592,610 with year one operating costs of $3,192,400 and year two operating costs of

$6,602,400. Seasons Hospice proposes five conditions. An in-depth description of

these proposed conditions is shown on pages 16 and 17.

Need/Access: Each applicant is responding to published need for a new hospice

program. Each applicant states that there is unmet need in Broward County, which ranged from access issues for minority populations including Hispanics, African-Americans, and Jewish persons, to patients

of nursing homes and assisted living facilities, and persons with end-stage heart disease; both cancer and non-cancer diagnoses in all age

cohorts were identified as not having proper access to hospice services.


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All applicants provided statistical data of underserved minority

populations in Service Area 10; however, none document that hospice care to minority residents is not available or accessible.

All co-batched applicants provided evidence that they have local support for their proposals to enter the service area. All applicants provided

letters of support from hospitals, skilled nursing facilities, continuing care retirement communities or assisted living facilities within the hospice service area. Seasons submitted the most letters of support from

within Broward County, including a letter from a community nursing home willing to enter into contractual arrangements. Compassionate

Care submitted no letters from Broward County providers stating intent to enter into contractual arrangements for hospice beds; Greystone submitted one letter from a provider willing to enter into contractual

arrangements (this provider submitted intent to contract for services with Seasons Hospice as well).

All applicants have agreed to measurable conditions, if awarded the CON, to ensure that its proposed program offers improved access to

hospice care and services in Broward County. The Agency’s need methodology that resulted in published need for a new

program in Broward County showed the projected number of admissions minus the current number of admissions for the January 2015 planning

horizon as 949. By a margin of just 13 total admissions, Seasons Hospice proposed the largest program to address this published need:

Total Projected Admissions By Applicant

for Years One and Two CON # Applicant Year One Year Two Both Years

10213 Seasons Hospice 229 408 637

10211 Compassionate Care 182 444 626

10212 Greystone Hospice 266 356 622 Source: CON application #’s 10211, 10212, and 10213.

Seasons, since entering the Service Area 11 market, greatly increased the admissions volume from the previous hospice operation. Douglas

Gardens Hospice reported 234 and 238 admissions for the 12 months ending September 30, 2009 and 2010, respectively. The previous two

years prior to Seasons ownership. Seasons reported 605 admissions for the 12 months ending September 30, 2011 and 869 admissions for the 12 months ending September 30, 2012.

Compassionate Care Hospice’s (6B CON application #10036) projected it would have 275 year one and 415 year two admissions. This program

was licensed in February 2011 and reported 164 admissions for the 12


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months of April 2011 - March 2012 and 358 admissions for the 12 months ending March 2013.

Quality of Care:

All applicants provided a discussion of their ability to provide quality care.

Agency records indicate that during the three-year period ending December 13, 2013, Compassionate Care had one substantiated

complaint; Greystone’s nursing homes had 64 substantiated complaints; and Seasons Hospice had zero substantiated complaints. Greystone has

no operational hospice programs. Seasons Hospice & Palliative Care of Southern Florida’s patient/family

satisfaction at 94 percent for Outcome Measure 1, 90 percent for Outcome Measure 2 and 100 percent for Outcome Measure 2A exceed

Compassionate Care Hospice’s patient/family satisfaction of 75 percent for Outcome Measure 1, 85 percent for Outcome Measure 2 and 96 percent for Outcome Measure 2A.

Financial Feasibility/Availability of Funds:

Compassionate Care Hospice of Broward, Inc. (CON application #10211) projected gross revenue was 1.6 percent, or $71,705, less than

the calculated gross revenue. Operating profits from this project are expected to increase from an

operating loss of $215,104 for year one to an operating profit of $729,076 for year two.

The parent did not provide a statement from any bank indicating the current available balance in the revolving line of credit, and without this

or current audited financial statements, we cannot rely on the information presented in the application that would support the parent’s ability to fund the project.

Funding for this project is in question.

Assuming the applicant can obtain the necessary financing; this project appears to be financially feasible.

Greystone Hospice of District 10 LLC (CON application #10212) projected gross revenue was 8.49 percent, or $411,974, less than the

calculated gross revenue.


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Operating profits from this project are expected to increase from negative $268,691 for year one to $327,135 for year two.

Funding for this project should be available as needed.

This project appears to be financially feasible.

Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON application #10213): The applicant failed to provide information detailing the patient days per service. Without this information, the

Agency cannot form an opinion on the reasonableness of the projected revenues. However, the applicant included a financial review provided by

Moore Stephens Lovelace, P.A., which indicated the project would have sufficient revenues to meet expenses.

Seasons is projecting a year one loss of ($390,000) and year two net profit of $302,100.

Funding for this project should be available as needed.

This project appears to be financially feasible. Medicaid/Charity Care:


#10211): Schedule 7A shows 1.3 percent of total annual patient days for charity care in years one and two of operations. Compassionate Care’s patient day Medicaid percentage is projected to be 3.0 percent for

years one and two of operations. Greystone Hospice of District 10 LLC (CON application #10212):

Schedule 7A shows the following patient days by payor: 3.9 percent Medicaid patient days for years one and two of operations, and one

percent self-pay for the first two years of the project. Seasons Hospice & Palliative Care of Broward Florida, Inc. (CON

application #10213): Schedule 7A forecasts 3.5 percent Medicaid patient days in years one and two of operations, and a combined 1.5

percent self-pay/other total patient days for the first two years of the project.

G. RECOMMENDATION

Approve CON #10213 to establish a hospice program in Hospice Service Area 10, Broward County. The total project cost $590,610, with year one


97

operating costs of $3,192,400 and year two operation costs of $6,602,400.

CONDITIONS:

1. Seasons Hospice & Palliative Care commits to provide at least two

Continuing Education Units (CEU) offerings per year for registered

nurses and/or licensed social workers at no charge through their nationally-accredited CEU programs by the Association of Social Work Boards and the American Nurses Credentialing Center. The

monitoring report for this condition will identify each course, provide a brief description of the content, and the dates and

location of the training. 2. Seasons Hospice & Palliative Care commits to offer internship

experiences for positions such as social workers, music therapists,

art therapists, bereavement counselors, chaplains, and medical assistants. We will seek local contracts as well as leverage existing

national contracts with the American Music Therapy Association, Everest College, Kaplan College, and the University of Southern California’s Virtual MSW Program. The annual monitoring report

for this condition will include a copy of the advertisements for interns in Broward County and the number of interns taking advantage of the program.

3. Seasons Hospice & Palliative Care of Broward Florida will donate $25,000 per year to Seasons Hospice Foundation restricted to wish

fulfillment (funding of wishes that enhance quality of life), emergency relief (funding basic needs such as food and shelter), education and research for Broward County residents. The

monitoring report for this condition will be a notarized statement confirming the contribution was made and will identify the check number, date and amount.

4. Seasons Hospice and Palliative Care commits to provide alternative therapies beyond the core hospice benefit, such as massage

therapy, music therapy, art, or other such alternative therapies when eligible and needed. Seasons shall provide no less than one full time equivalent (FTE) per 100 patients served on an average

daily basis in Broward County. The monitoring report for this condition will identify the number of FTEs by the type of

alternative therapy provided in Broward County. 5. Seasons Hospice & Palliative Care commits to voluntary reporting

of the Family Evaluation of Hospice Care survey to the Agency.

The survey report serves as the monitoring report.

Deny CON #’s 10211 and 10212.


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AUTHORIZATION FOR AGENCY ACTION

Authorized representatives of the Agency for Health Care Administration adopted the recommendation contained herein and released the State Agency Action Report.

DATE:

James B. McLemore

Health Services and Facilities Consultant Supervisor Certificate of Need

Jeffrey N. Gregg

Director, Florida Center for Health Information and Policy Analysis

Date post:	23-Jun-2020
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