St. Dominic-Jackson Mem'l Hosp. v. Madison HMA, Inc.
| Docket Number: | 2006-SA-00281-COA | |
| Oral Argument: | 01-23-2007 | |
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| Court of Appeals: |
Opinion Link Opinion Date: 04-17-2007 Opinion Author: LEE, P.J. Holding: Affirmed |
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| Additional Case Information: |
Topic: Certificate of need - Relocation of facility - Substantial evidence Judge(s) Concurring: King, C.J., Myers, P.J., Irving, Chandler, Barnes, Ishee and Roberts, JJ. Non Participating Judge(s): Griffis and Carlton, JJ. Procedural History: Admin or Agency Judgment Nature of the Case: CIVIL - STATE BOARDS AND AGENCIES |
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| Trial Court: |
Date of Trial Judgment: 01-30-2006 Appealed from: Hinds County Chancery Court Judge: William H. Singletary Disposition: MISS. STATE DEPT. OF HEALTH ISSUED A CERTIFICATE OF NEED TO MADISON HMA, INC. D/B/A MADISON COUNTY MEDICAL CENTER. THE CHANCELLOR AFFIRMED THE DECISION. Case Number: G2005-2127-S2 |
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| Party Name: | Attorney Name: | |||
| Appellant: | ST. DOMINIC-JACKSON MEMORIAL HOSPITAL |
JONATHAN R. WERNE,
EDMUND L. BRUNINI, JR. |
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| Appellee: | MISSISSIPPI STATE DEPARTMENT OF HEALTH AND MADISON HMA, INC. D/B/A MADISON REGIONAL MEDICAL CENTER | ANDY LOWRY, ALLISON C. SIMPSON, THOMAS L. KIRKLAND, JR., DONALD E. EICHER, III |
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| Topic: | Certificate of need - Relocation of facility - Substantial evidence |
| Summary of the Facts: | Madison HMA, Inc., d/b/a Madison County Medical Center filed a certificate of need application to relocate and replace its entire sixty-seven bed hospital in Canton. In its application, Madison HMA sought to completely replace its current 59,930 square foot facility built in 1965 with a 122,000 square foot facility in a more accessible location. St. Dominic contested the application. At the conclusion of the hearing, the hearing officer recommended that the application be approved, and the State Health Officer concurred with the hearing officer’s recommendation and issued the CON. St. Dominic appealed to chancery court which affirmed. St. Dominic appeals. |
| Summary of Opinion Analysis: | Madison HMA does not seek to duplicate any services, since MCMC’s existing facilities and services will be completely relocated to the Nissan Parkway, and the current facility will be closed. No public funds will be used in the construction of the new facility since HMA is a private, tax-paying entity and is thus providing all the funding for the project. Madison County will receive the benefits of a modern hospital without spending city or county money, and the City of Canton may ultimately see an increase in tax revenue from the upgraded, more attractive facility. The Department had substantial evidence to determine extra costs were necessary because the new facility will provide more comprehensive health services. Overwhelming evidence was presented at the hearing about the poor condition of MCMC’s current facility. The new facility will use eight of the sixty-seven beds currently in use to establish an intensive care unit to better serve the needs of patients. MCMC is currently difficult to access for most patients. The new location will be more convenient for the residents of Madison County and the people in and north of Canton as it will be located just off Interstate 55. The replacement facility will continue to serve all patients, and it will better serve handicapped patients as it will be ADA compliant. Thus, substantial evidence existed for the Department to conclude that MCMC’s CON application met the four goals of the State Health Plan. St. Dominic argues that the planned capital expenditure on the new hospital facility is excessive when compared with other recent replacement projects and that no justification was given in the application for the excessive cost. From the testimony presented at the hearing, the hearing officer could not find that the costs associated with the project were unreasonable under the circumstances. St. Dominic also argues that the Department could not verify that the financial projections were accurate, and, thus, the financial feasibility of the project could be at issue. However, St. Dominic offered nothing to support its proposition that the financial projections were inaccurate at the hearing. St. Dominic argues that relocation of facilities is not recognized as a necessary remedy to aging facilities. However, the hearing officer had substantial evidence to justify his ruling. During the time of construction, patients in the Madison County area would be left without a nearby hospital. Given that the hospital would be effectively closed, physicians may choose to move their practices to facilities elsewhere during the renovation. St. Dominic argues that Madison HMA did not consider renovation or replacement of MCMC at the current location. Madison HMA presented several reason why renovation was not practical. For example, renovation would be limited because of land constraints. Further, renovating does not solve the problem of the current facility being in a poor location. Madison HMA presented ample evidence that the current facility is too outdated to be brought up to current standards. Even in light of the problems pointed out by St. Dominic, the Department’s decision was based on substantial evidence. |
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