Another certificate of public advantage report concludes that Ballad Health’s communication with the community has been ineffective.
The 11-page report by COPA Monitor Larry Fitzgerald recommended that the merged hospital system give consideration to the usage of external resources for communication activities, urging that “all communication vehicles should be used.”
In his report, Fitzgerald notes that “many of the citizen comments expressed at the (local advisory council) public meeting would have been averted had communications been effective.”
Ballad’s communication with the 21 counties in its jurisdiction is one item on the laundry list of issues critics of the merger have cited at public forums and during meetings.
According to the report, Ballad’s standing executive leadership meetings are currently closed to the COPA Compliance Officer. Fitzgerald proposes a change in his second recommendation of the report.
“The COPA Compliance Officer is not involved in discussions and decisions that have an impact on the COPA or (terms of certification),” he writes in the report. “If the COPA Compliance officer is not included as a partner and active executive leader, this part of the active supervision may be negatively impacted.”
As part of the terms outlined in the TOC, Ballad Health must invest $308 million over 10 years in specific areas such as access to healthcare services, population health improvement and a health information exchange.
Ballad is committed to investing $8 million for the year ending June 30. If Ballad’s annual spending in any of the commitment areas is short by more than 15 percent, it constitutes noncompliance and could result in a fine of up to $1 million.
Fitzgerald’s report says that the Monitor may recommend no fine be leveled against Ballad because of “extenuating circumstances.”
“Primarily, as a result of the startup of this merged organization, it is likely that a part of the year one financial commitment will be delayed but be caught up within the first three years,” the report said.
Sub-index scores, such as those for population health and access to health services, were not readily available due to the absence of some baseline scores. Sub-index scores will be ready after June 30, the report said.
Since he was appointed as COPA monitor in June, Fitzgerald said in his report that he visited Ballad’s corporate office two to three days out of each month in addition to touring the system’s facilities.
Critics of the merger argue that someone in a supervisory role should spend more time on the ground floor.
The TOC also requires Ballad increases charity care each year following the merger. Ballad reported about $80 million in charity care for the base year ending June 30, 2017, and the first year to measure will end June 30 this year.
Once again, the Monitor can waive the charity requirement due to extenuating circumstances, and Fitzgerald notes in his report that Virginia’s Medicaid program expansion might alter those numbers for this year.
“It is likely the Ballad Health charity care will drop for the year ending June 30,” he writes.
Fitzgerald writes in his report that his focus on the next 12 months will include:
- Preparing recommendations to the Tennessee Department of Health for changes to the 35 percent rule, which limits the employment of physicians.
- Preparing a report on adherence to the Addendum 1, a section designed to restrict the number of price increases Ballad can negotiate from non-governmental payers, and developing a proposal for an improved Addendum 1 to the health department.
- Continue monthly on-site visits.
In his summary, Fitzgerald notes that most of the report focuses on activities that happened after the reporting period which ended June 30, 2018.
He listed accomplishments including three-year plans for behavioral health, children’s services rural health services and population health improvement along with establishing new charity care policy while managing a newly-merged company.
“There is much to be done to demonstrate continued public advantage, but I believe Ballad Health has begun this journey successfully,” he concludes.