Broadlands Hospital

The Broadlands traffic information can be found in "Broadlands Regional Medical Center -- Traffic Impact Analysis," May 20, 2008 (and updated Aug 6, 2008). By the way, the VDOT review of that report recommended using the Square Foot variable rather than the number of beds. Ref for that is VDOT Letter dated Jul 11, 2008.

For comparison purposes, I cited the following studies:

Albert Einstein Healthcare Network (AEHN) proposal for a 190-bed facility of 380,000 square feet and a 75,000-square-foot medical office building (suburban Philadelphia) traffic impact analysis conducted by Traffic Planning and Design, Sep 8, 2008.

Columbia Town Center, Short and Long Term Traffic Assessment, conducted by Sabra, Wang & Associates, Inc, Oct 11, 2007. This included a 114,000 SF expansion to the curent hospital (42 additional beds) and 160,000 SF medical office building.

 

Thanks!

 

And people believed what the seller of the homes told them?! I'm sorry, that is "blindly". Before we bought our home, I went to the Planning Department in Leesburg and asked them to show me what was going where. A home purchase is the biggest investment you make. It deserves a bit of independent investigation.

Homes that are near undeveloped commercial property sell at a discount to those that do not. People that buy them gamble that the discount obtained today will not be overcome by a potential loss of value in the future when the site is actually developed.

It is not. I have worked at industrial complexes and a hospital is not one.

-Jim

 

Just a note, I sent an email to the supervisors and commissioners, and the replies I'm getting back seem to be along the same lines... they appreciate the input and will consider all info they are sent, but ultimately this is a land use application, and they will make their decisions based on land use issues.

 

For those of you that appreciate both sides of an issue, here is Dean Montgomerys response to the EriK Bodin Letter...


Health Systems Agency of Northern Virginia
7245 Arlington Boulevard, Suite 300
Falls Church, Virginia 22042
Phone: 703-573-3100 Fax 703-573-3103
Email: hsanv@aol.com






October 24, 2008



Erik Bodin, Director
Division of Certificate of Public Need
Virginia Department of Health
9960 Mayland Drive, Suite 401
Richmond, VA 23233

Dear Erik,

I recently received a copy of the October 15, 2008 email message you sent Thomas Hancock regarding the Virginia certificate of public need (COPN) significant change process (enclosed).

The message references "misconceptions concerning the significant change process" and a desire to "provide some clarity from DCOPN's standpoint". The misconceptions alluded to are not identified, but you opine at some length on how a proposal to change the location of Broadlands Regional Medical Center (BRMC) would be handled by your office. The information provided raises a number of troubling questions. The content, tone, and process used to generate the message are problematic.

Please consider the following discussion and determine whether a retraction or additional clarification is necessary.

1. The assertion that the 35 day review period called for in the applicable Virginia COPN regulations is “aspirational” rather than mandatory is simply factually wrong and misleading at best. The use of the term “aspirational” in a regulatory context is novel. The language of the regulation (12VAC5-220-130) is not equivocal. It reads in part

“The regional health planning agency shall review the proposed change and notify the commissioner of its recommendation with respect to the change within 30 days from receipt of the request by both the department and the regional health planning agency. Failure of the regional health planning agency to notify the commissioner within the 30-day period shall constitute a recommendation of approval. The commissioner shall act on the significant change request within 35 days of receipt.” (12VAC5-220-130)

Erik Bodin
October 24, 2008
Page 2

The review time limits set for the regional health planning agency and the Commissioner of Health are mandatory, not permissive. The review period may be extended with the permission of the applicant, but not unilaterally by the regional planning agency or the state COPN program and is not customarily extended for any significant period.

Nearly all significant change requests, including the request earlier this year that extended the period of time permitted for the development of Broadlands Regional Medical Center, are handled promptly, within the prescribed time limits. Statements to the contrary, and language that permits or encourages those not familiar with the process to conclude that significant change requests entail lengthy review and extensive analysis, are not accurate.

2. The suggestion that developing Broadlands Regional Medical Center (BRMC) in the Dulles South (South Riding) area would entail relocation of the hospital to a new (different) primary service area is not correct. Both the developers of BRMC and the Virginia Division of COPN consistently have assumed and acknowledged that BRMC’s primary service area would be all of Loudoun County, not just the area near or surrounding Ashburn. Moreover, both Ashburn (including Broadlands) and South Riding are in eastern Louduon County.

Potential hospital sites on Route 50 are about seven miles from the proposed Ashburn site.
Arguably, developing the new hospital on Route 50 rather than in Ashburn would result in better distribution of hospital capacity in the County, but the primary service area of both the new hospital and Inova Loudoun Hospital would (will) remain the entire county, especially the more densely populated eastern half of the county.

3. The concern that developing the new hospital on Route 50 rather than in Ashburn would be likely to affect other service providers negatively, and this would be a significant factor in considering a significant change, is misplaced. Patient origin and destination data relied on in the analysis of the original BRMC COPN application show conclusively that whether at Ashburn or on Route 50 the principal (larger) negative effects on demand and market share would be at Inova Loudoun Hospital (ILH).

A hospital in South Riding would have less negative effect on ILH than one in Ashburn. Building in South Riding rather than in Ashburn, therefore, would reduce the concern about a large negative effect on an existing hospital.

A different location for BRMC would have differing effects on hospitals less negatively affected. Shifting the location of the new hospital to Dulles South would reduce the likely negative effect on demand at Reston Hospital Center and increase the negative effect on Inova Fair Oaks Hospital. The owners/operators of all three of the hospitals that might be affected by a shift in location were fully engaged in the planning and regulatory processes that led, ultimately, to the issuance of a COPN for the development of BRMC in Ashburn.

Erik Bodin
October 24, 2008
Page 3


A shift in the location of the new hospital to any of the sites within Loudoun County would have only small negative effects on Prince William Hospital or Fauquier Hospital.

4. The statement that “much of the review that led to the original, site specific, approval would need to be repeated looking at the new site” is not on point and potentially misleading. Both the regional and the state level reviews of the proposal to develop BRMC focused on the need for an additional hospital (additional hospital beds and related capacity) in Louduon County, not on the specific site chosen by the developer. The site was chosen by the developer. The regional planning agency and the Commissioner of Health responded to the developer’s proposal. Neither determined that Ashburn is the appropriate location for a new hospital.

As a practical matter, certificates of public need are necessarily site specific. That does not mean that COPN reviewers have determined that the sites chosen by developers are the best locations for the service proposed. Historically, the Commissioner and regional planners have understood and acknowledged that specific service development sites are determined by local land use policies and practices.

5. The suggestion that a significant change review of a proposed site change for BRMC would entail a full review “against the same current criteria used to determine the need for any new hospital placement, including population, geographic access, impact on existing providers, etc.” is misleading. The character and tone of this language would lead most people to believe (assume) that a shift in the location of BRMC would entail a de novo review equivalent to the review of the original COPN application. That, of course, is not correct. The need for the hospital and many other basic planning considerations would not be subject to reconsideration.

Given that both the Division of Certificate of Need and the regional planning agency found that BRMC was (is) not needed, the language used would imply, and lead many to believe, that the relocation would be denied. This, too, is incorrect. By their nature, significant change requests tend to be approved routinely, promptly. In the last two decades, no significant change request for a site change in Northern Virginia has been denied.

There is no reason to believe that a request to change the location of BRMC would be handled differently or that the outcome would be different. It is instructive that the Commissioner of Health has already approved a significant change extending the time permitted to begin construction of BRMC, notwithstanding the opposition of the regional planning agency. That significant change authorization, which arguably is more substantial than a site change within the County, was handled promptly without a public hearing, within the 35 days permitted by the regulations.

Erik Bodin
October 24, 2008
Page 4


6. The characterization of the action of this agency on the proposed development of a CT scanning service in the Dulles South (South Riding) area is factually incorrect and fundamentally misleading. HSANV opposition to the development of a new CT scanning service in South Riding was not based on the size of the population in the area but on the objective fact that a CT scanning service has just opened nearby (less than a mile distant) in the area. A second scanner simply was (is) not needed. Inexplicably, the Division of
Certificate of Need analysis of the proposal excluded any reference to, or recognition of, the existing service. It does exist and is now serving the South Riding area.

7. The concluding statement of the email message is especially troubling. It appears either to speak for or, in the alternative, advise both the Health Systems Agency of Northern Virginia and BRMC on the question of the potential site change for the hospital. Apparently, DCOPN has concluded that HSANV would not support a significant change request and that a change in location is not a “viable option” for BRMC. This language, and these views if they accurately reflect COPN program thinking, call into question the judgment and objectivity of the program.

The Health Systems Agency of Northern Virginia has taken no position on a possible relocation of BRMC.

Taken as a whole, the October 15 document is as extraordinary as it is flawed. Surely, the views expressed, and the manner in which they are expressed and conveyed to selected interested parties, do not represent the considered judgment and official positions of the COPN program or the Commissioner of Health. That is, of course, how many will interpret them. On reflection, further clarification may be warranted.

Please let me know if you have questions, or if I have failed to understand or otherwise appreciate the nature and intent of your remarks.

Sincerely,

Dean Montgomery
HSANV

Cc: Lee Draznin, Chairperson, HSANV
Virginia Regional Health Planning Agencies
Karen Remley, MD, MBA, Commissioner of Health
Christopher Durrer, Director, OLC, VDH
HSANV Board of Directors

 

Who/What is HSANV?

 

Health Systems Agency of Northern Virginia
General Purpose

The Health Systems Agency (HSANV) of Northern Virginia is a nonprofit organization established under Virginia law to plan for the balanced and orderly development of health care facilities and services in Northern Virginia (Virginia Health Service Area II).
Members

There are 30 members, two of whom are appointed by the Loudoun County Board of Supervisors.
The majority of HSANV members must be consumers who are broadly representative of the health service area. These should include individuals representing the principal social, economic, and racial populations of the area. Remaining members are provider members who must be representative of a wide range of health care professionals. A reasonable balance of providers and consumers is sought.


---

Dean Montgomery is the Executive Director of the HSANV.

And, agreed to an earlier comment... HSANV certainly has taken a position on the relocation of BRMC, as a CalNurses press release from May 2008 clearly shows (odd, why does a California nursing union care about a NoVa hospital? Oh yeah, because they're helping CCoB fight it...):

http://www.calnurses.org/media-cent...l-of-extension-for-proposed-hca-hospital.html

If [sic] fact, HSANV explained how HCA, acting through its subsidiary Northern Virginia Community Hospital (NVCH), explicitly ignored an opportunity to move forward at another site: "The argument that events beyond the control of NVCH have prevented progress is tendentious at best. NVCH has had available throughout the last three years the alternative of locating Broadlands Regional Medical Center at a nearby site in the South Riding area of Loudoun County where hospital development is encouraged and zoning approval is readily available...."



Yeah... not taking a position, indeed.

 

Not to say taking a position is a bad thing, since that's HSANV's job.
However, saying they don't take a position when it's clear they do... that's... well...
tendentious at best.

Sorry, couldn't resist.

 

Come on, Dean and HSANV are hacks for Inova and all non-profit hospitals. Prince William Hospital and HSANV objected to the location of the CT scanner on Rt. 50 - despite Dean's revision of history - and they'd fight a relocation of BRMC down there too. Read the Leesburg Today story (http://www.leesburg2day.com/articles/2008/11/18/news/fp361hospital111708.txt) that says the County's numbers say 83% of the population in the County is closer to the Broadlands that Rt. 50 (BRMC says its 90%, don't care which number it is). This is about what is best for all of Loudoun County, not just Inova.

 

I still can't believe that we have an arm of government (for which we pay) whose job it is to tell the private sector how much they can invest in their business. Is there a parallel in any other piece of the American economy, such as it is?

On second thought, perhaps we need more of these types of agencies. I propose:

1. The Nail and Hair Care Allocation Administration
2. The Virginia Martial Arts and 24 Hour Fitness Development District
3. The Northern Virginia Supermarket Location Commission

We would not want the market to make investments and compete to provide the best services. We need a very learned and wise official of the Appartus to ensure that we get what they determine we need. This type of approach has worked very well in other planned economies ;-)

-Jim

 

ketchup-
Right on the money. All you need for evidence is to review Mr. Montgomery's record on profit versus not-for-profit hospital applications.
Also, he does not issue COPN's.
Nice try by the Inova employee, but still falls far short of any significance.

Oh, and one last point.......NOBODY WANTS TO BUILD A HOSPITAL ON RTE 50 NOW!!!!

 

Last night's hearing at Stone Bridge was very interesting. When one of the speakers asked who opposed the hospital in Broadlands, at least 75% of those in attendance stood up. A remarkable show of opposition. Although their reasons for opposition varied, they did not feel that Broadlands was the best location for the next Loudoun hospital. Sorry you had to leave early, Cliff. Many of those who spoke in favor of BRMC had axes to grind with Inova Loudoun, so they would be happy to see competition anywhere in Loudoun. By the way, a large number of the people in attendance (over 100) actually want the hospital to built along Rte 50. As does Inova Loudoun. HCA has even drafted an amendment to their COPN application to request a change of location for the hospital to be built along Rte 50. That sounds like a win-win situation for everyone -- to locate the hospital along the Rte 50 corridor. Ironically, that location still provides a third hospital within 20 mins drive of our Broadlands community, but more importantly provides greater access to health care services for the residents of southern and western Loudoun County.

 

http://loudounextra.washingtonpost..../2008/nov/21/few-highlights-hospital-hearing/
Here is another perspective in which the reporter states it was evenly split.

I live south of Broadlands and I can tell you I don't want to travel to RT 50 for any of my needs. There is absolutely no transportation infrastructure and just one option to get there down a hodgepodge of 2-lane roads, similar to the accessibility for those who live out in Western Loudoun county. BRMC has 4 options immediately available.

 

I'm sorry I missed it! Were those 75% primarily made up of people wearing white t-shirts, brought in by INOVA on buses again to take up seats for actual Broadlands/Loudoun/Virginia residents? Or were the attendees this time people who actually had business being there?

 

* clap clap clap clap *
This is just more proof that we have a great county supervisor in our district.
From http://loudounextra.washingtonpost....session-hears-more-150-speakers-proposed-hos/


"Miller suggested that people who speak at a public hearing as part of their paid job should be last on the list so others can comment and leave earlier. He said that he might ask the board to approve such a stipulation for future land-use applications and to require that paid speakers indicate they are being paid."

 

Space guy, I was there, 75% is a big exaggeration. The person you are referring to that ask for people to stand was Ms. Paice, the INOVA paid representative for the bogus Citizens Against Broadlands Hospital.

Now were you still observing when Mr. Kelly Loudoun Hospital CEO spoke, did you see that same crowd you referred to, cheer for him? That group is his employees. They have been told repeatedly that they will lose their jobs if BRMC is built. Told this by Kelly, so a little manufactured fear was on display that night. Certainly there were some there that actually live on 50 or live in Broadland's and oppose the hospital, but the overwhelming numbers you reference where there to support Kelly's mission.

A mission to fight the competition and save the monopoly. It's all about corporate greed.

 

IMO, spaceguy is "probably" an Inova employee or supporter. Every one of his(?) posts are related to the hospital issue.

 

That is one he*l of a good idea!