PDPM Implementation Webinars for MDS

To: Federally Certified Skilled Nursing Facilities Administrators, Directors of Nursing, MDS Coordinators, Billing and Coding Personnel, Licensed Nursing Facilities Administrators 

From: The Health Facilities Education and Quality (HFEQ) Branch of the Health Facilities and Emergency Medical Services Division (HFEMSD)

The Patient-Driven Payment Model (PDPM) is coming for all MDS 3.0 submissions with an Assessment Reference Date (ARD, A2300) on or after October 1, 2019. This will have implications for submission to the Federal database (OBRA and optional Interim Payment Assessments) for Medicare reimbursements. There will be additional considerations for State reimbursements via Medicaid for using the Optional State Assessments (OSA).

Explanatory webinars are planned to introduce these changes. Participants will identify State contacts for questions and further information.

Each webinar will have course materials available before the sessions. It is important to register via Train.org, and to allow Train to send email notifications to receive the call-in times and URL. Multiple participants are welcome per phone line.

PDPM Practice Webinars (ID 1086630) This series of 5 one-hour weekly webinars will compare and contrast the current Prospective Payment System (PPS) with upcoming PDPM concepts and requirements.

– Intro – Adjustments and additions to the Item Set will be discussed. The new Interrupted Stay policy will be explained. A framework for the calculation of PDPM payments using the new HIPPS codes will be introduced. The webinar will be a prerequisite to further PDPM Practice Webinars because of terminology.
– Case 1 – Admit with Infection 
– Case 2 – Admit for Procedure Aftercare 
– Case 3 – Acute Infection becomes Pneumonia 
– Case 4 – Complex Surgical Aftercare

Using the Optional State Assessment (OSA) for Medicaid Nursing Home Residents in Colorado (ID 1086621)

This will be a joint webinar between the Colorado Departments of Public Health and Environment (CDPHE) and Health Care Policy and Financing (HCPF) to clarify the use of OSA for nursing homes. Medicaid requirements and timelines will be explained, and practical examples of MDS 3.0 items will be reviewed. There will be time for Q&A. To see additional session details and register for session materials for one of these offerings:

1. Go to http://www.train.org/ 
2. Log in to your existing CO.TRAIN account, or new users click “Create an Account”.
3. Once you’ve logged in, or created an account, Search (top right) for the appropriate Course ID. (See above for desired training)
4. Click link for desired course. Note open session options.
5. Click the “Register” button for the session you wish to attend.
6. Remember to register separately for each desired course.

Detailed Instructions for Using Train.org (if needed)

Questions?: Please email betty.metz@state.co.us


Join NHSN Colorado Group Monthly Webinar on 8/14/2019

Please join us at our next monthly webinar on Wednesday, August 14, 2019.
to https://zoom.us/meeting/register/0f4853b4057656868c34be5db4a05ad8,
to register for the webinar. The monthly webinar is held on the second Wednesday
of every month from 1p.m. – 1:30 p.m. (MST).

The Colorado Department of
Public Health and Environment is hosting a monthly NHSN Colorado user group
webinar to provide updates and training related to NSHN. The purpose of the
monthly webinar is to provide updates and training on various topics to the
licensed facilities in Colorado who report in NHSN. Immediately following the
webinar, CDPHE staff will be available to assist new users in NHSN set-up,
enrollment and other facility specific questions.


– Demonstration of Custom Reports
– Q & A

questions, please contact Lynda Saignaphone at 303-692-2923, lynda.saignaphone@state.co.us.

Reminder – Assisted Living Advisory Committee meeting on Thursday, August 22, 2019

To: Assisted Living Residence Providers and Stakeholders 

From: Dee Reda, Community Services Section Manager

The next Assisted Living Advisory Committee meeting is on Thursday, August 22, 2019 from 1:30 p.m. – 3:30 p.m. in Building A, Sabin/Cleere Room.

For meeting agendas, handouts, etc. please go to: https://drive.google.com/drive/folders/0ByqZDBabyNVSR3pNejg2X2J0V2c?usp=sharing%20. Click on the folder labeled “2019 Meetings” and find the corresponding meeting date. We recommend that you return to this site on the day of the meeting to check for additional or revised meeting materials. 

To participate via Web using Zoom Meetings: 
Join from PC, Mac, Linux, iOS or Android: https://zoom.us/j/881545146 

Meeting ID: 881-545-146

Step #1: Go to https://zoom.us/j/881545146 
The Zoom meeting screen will appear entitled “Assisted Living Advisory Committee”
Step #2: For sound, choose Phone Call or Computer Audio.
Step #3: You will now be in the Virtual Meeting Room.

If you have never attended a Zoom meeting before:
Get a quick overview: https://support.zoom.us/hc/en-us/articles/204772869-Zoom-Rooms-User-Guide

To participate by telephone:
Step #1: Dial (for higher quality, dial a number based on your current location): US: +1 669 900 6833+ or 1 408 638 0968 or +1 646 876 9923
Step #2: When prompted, enter the Meeting ID: 881 545 146
Step #3: You will be on hold until a few moments before the meeting.

If you have any questions, please contact Michelle Topkoff at michelle.m.topkoff@state.co.us or call 303-692-2848 at least a business day in advance of the meeting. 

Meeting information

At the Colorado Department of Public Health and Environment, we work hard to protect and promote your health and the environment. If you’re planning a visit to our campus and want to ride your bike here, we won’t take a second look at your helmet head, and if the bus you’re taking is running a little late, we won’t worry. We want you to be your healthiest you, and we appreciate your efforts to reduce pollution.
If you’re coming to our campus: Our campus is located at 4300 Cherry Creek Drive South, Denver, 80246.
If you’re riding your bike: Our campus is located just south of the Cherry Creek bike trail. Bicycle parking is available at multiple locations on the main campus. Covered bicycle parking also is available at several locations, as well as on the ground floor of the parking structure on Birch Street, which is just east of the main campus 
If you’re riding the bus: RTD’s Trip Planner is a great way to find the fastest route.
If you’re driving: Visitor parking is conveniently located in front of all of our buildings. Please check in with security in Building A so you can get a visitor badge.
You might also want to know:
We care about your health, so our campus is tobacco-free.
We are located just east of Glendale’s City Set, where there are several restaurants.
Lactation Rooms are available on the first floors of buildings A and B. 

Chapter 7 Assisted Living Regulation Updates and Resources:

Updates on the Chapter 7 Assisted Living Regulations can be found on the Assisted Living News & Resources web page at

It is our hope that this resource will provide you with up-to-date and relevant tools, training, and information, as we move forward with implementing the new regulations under 6CCR 1011-1, Chapter 7 Assisted Living Regulations. Current features of the newsletter include on “What’s New”, “Important Dates,” “Training,” “Blog,” “FAQs”, “Help” and “Advisory Committee”. Our goal is to provide you with a clear understanding of the new portions of the regulation as well as training to help you comply. 

HHA IDR Committee Meeting

This blog publishes information typically sent through the Health Facilities Web Portal to health care entities regulated by the Colorado Department of Public Health and Environment. Please note that the Web Portal is the official medium for business communication between the Department and licensed and Medicare/Medicaid certified health care entities. Health care entities should continue to monitor their portal accounts routinely.

Chapter 4 Hospital Rule Revision meeting information

Dear Stakeholder:

In keeping with the statutory requirement to routinely review and update our regulations, the department is beginning the stakeholder process this October for the regulatory review of 6 CCR 1011-1, Chapter 4 – General Hospitals, Chapter 10 – Rehabilitation Hospitals, Chapter 18 – Psychiatric Hospitals, and Chapter 19 – Hospital Units. These chapters cover a wide range of topics that impact hospitals, both general and specialty. 

The stakeholder meeting schedule and detailed information regarding the rule revision process can be accessed at this link https://drive.google.com/drive/folders/1yTm15HQ_6pOdnL_jn9Lj1mpUUB6r-5qV

ALR IDR Committee Meeting

This blog publishes information typically sent through the Health Facilities Web Portal to health care entities regulated by the Colorado Department of Public Health and Environment. Please note that the Web Portal is the official medium for business communication between the Department and licensed and Medicare/Medicaid certified health care entities. Health care entities should continue to monitor their portal accounts routinely.

Behavioral Health Entity Implementation & Advisory Committee: Applications Now Available

To: Behavioral Health Providers, Consumers of Behavioral Health Services, Advocates and Interested Parties

From: Jill Hunsaker-Ryan, MPH, Executive Director, Colorado Department of Public Health and Environment

The Health Facilities and Emergency Medical Services Division of the Colorado Department of Public Health and Environment (CDPHE) is currently accepting applications for the Behavioral Heath Entity Implementation and Advisory Committee (BHE-IAC). 

Per statutory requirements with the passage of House Bill 19-1237, specifically addressing the development of a licensing structure for Behavioral Health Entities (BHE), the Colorado Department of Public Health and Environment has a responsibility to establish, facilitate and streamline minimum standards and regulations for BHE’s in the State of Colorado. The intent of creating the Behavioral Health Entity License is to:

– Provide a single, flexible license category under which community-based behavioral health service providers can provide integrated mental health disorder, alcohol use disorder, and substance use disorder services and meet a consumer’s continuum of needs, from crisis stabilization to ongoing treatment;
– Provide a regulatory framework for innovative behavioral health service delivery models to meet the needs of both individuals and communities;
– Increase parity in the oversight and protection of consumers’ health, safety, and welfare between physical health and behavioral health regardless of the payment source; and to lastly,
– Streamline and consolidate the current regulatory structure to enhance community providers’ ability to deliver timely and needed services, while ensuring consumer safety. 

In order to accomplish such a charge, HB 19-1237 established the Behavioral Health Entity Implementation and Advisory Committee. The BHE-IAC is responsible to:

– Offer advice to CDPHE and the State Board of Health concerning the phased-in implementation of the BHE license, rules promulgated by the State Board pursuant to C.R.S. 25-27.6-101 et seq., and the implementation of the BHE licensing transition;
– Provide ongoing advice to CDPHE regarding Behavioral Health Entities and Behavioral Health Entity licensing; and
– Identify a coordinated and aligned process of sharing information across state departments to ensure behavioral health services are available to all residents of Colorado. 

The BHE-IAC meetings will occur on a recurring monthly basis, taking place on the second Thursday of each month, beginning October 10, 2019. Meetings are anticipated to be three hours in duration. If you are interested in serving as a committee member, please complete the application and supplemental documents located here: 

Behavioral Health Entity Implementation & Advisory Committee Application 

All applications are due no later than close of business Friday, August 30th. Any questions may be directed to Crystal Cortes at either 303.692.2917 or Crystal.cortes@state.co.us

Thank you in advance for your interest!

Small ALR Facility Workgroup meeting August 27, 2019

To: Assisted Living Residence Providers and Stakeholders 

From: Elaine McManis, Health Facilities and Emergency Medical Services, Deputy Division Director

The next Small ALR Facility Workgroup meeting will be August 27, 2019, 1:30-3:30 p.m., Building C, Room C1D on our Cherry Creek Campus. 

All non-CDPHE staff must sign in with security in Building A and get a guest badge before proceeding to Building C.

*Due to space constraints, non-workgroup members are invited to attend by phone.

To participate by telephone:
Step #1: Dial 1-712-770-8066 
Step #2: When prompted, dial participant passcode 727084
Step #3: You will be on music hold until a few moments before 2:00 P.M.
Step #4: Very important: Please press 4* and mute your telephone to prevent background noise. 

If you would like to make a comment or ask a question, press 4* to unmute. When you are finished talking, please re-mute your telephone using 4* again. 

Very Important: Do not use speakerphones or wireless headsets; they are not compatible with the audio conferencing technology.

Meeting documents can be found at: https://drive.google.com/drive/folders/1NNrHpgqtwZHG51sOk3JTEMXXM7mgI0JW

OASIS D and D1 Classes *FREE*

To: Federally Certified Skilled Home Health Facilities Administrators, Directors of Nursing, OASIS Coordinators, Billing and Coding Personnel, Licensed Home Health Facilities Administrators

From: The Education and Technical Assistance (ETA) Branch of the Health Facilities and Emergency Medical Services Division (HFEMSD)

ETA will offer classes on specific OASIS topics in Longmont, Denver, Pueblo and Aurora featuring OASIS D items and OASIS D1 transition guidance. Most classes are almost full. You may choose to take sessions all at once or individually as your interest and needs dictate. All registration is first-come, first-served, even for sessions within a hosting facility.

ETA reserves the right to cancel classes with low registration. Early registration is helpful.

OASIS D Basics (One Session): Course ID 1082008
This beginning three-hour class is how to get started with OASIS D.

OASIS D Item-by-Item (2 Sessions): Course ID 1082009
This practical application class reviews item-by-item data set completion. We will follow Mrs. Green’s assessment, which will require two sessions to complete. Attendance at both sessions is required to complete this class.

OASIS Quality Measures (One Session): Course ID 1066910
This course assumes familiarity with the OASIS D Item Set, covering more advanced content and application.

To see additional session details and register for on-site attendance for one of these offerings:
1. Go to http://www.train.org/ 
2. Log in to your existing TRAIN account, or new users click “Create an Account”
3. Once you’ve logged in, or created an account, Search (top right) for the appropriate Course ID. (See above for desired training)
4. Click link for desired course.
5. Click the “Registration” tab.
6. Click the “Register” button for the session you wish to attend.
7. Remember to register separately for each desired course.

A detailed example of the above process (if needed)

Questions?: Please email betty.metz@state.co.us

A Sale of One Residency Program – the Commercialization of Health Care and now Residents Treated Like "Assets"

We recently posted (here and here) about the decline and impending closure of a once major urban safety-net teaching hospital, the Hahnemann University Medical Center.  This was the final common pathway of a downhill progression for an over 170 year old institution.

[Hahnemann Hospital in 1925]

Since the 1990s, it had been a non-profit university academic medical center, which was then merged into a non-profit health care system (Allegheny Health Education and Research Foundation, or AHERF), which was mismanaged into a bankruptcy of historic proportions (look here).  After that, the hospital wound up part of the  for-profit Tenet chain.  Two years ago, after reportedly losing millions of dollars a year for its corporate owner, it was sold to a private equity group, Paladin Healthcare, and made part of their American Academic Health System LLC.   Now, the new owner decided it was losing too much money, and declared bankruptcy.

The final closure of Hahnemann left patients, often indigent or vulnerable, with no ready source of health care, and thousands of health care professionals and staff without their jobs.  New coverage of these events revealed in particular the plight of the hospital’s nearly 600 house staff.

The Plight of the Residents

On July 10, 2019, a Medscape article summarized the state of play:

The 570 residents who started their programs just more than a week ago at Hahnemann University Hospital in Philadelphia, Pennsylvania, are scrambling to find new positions in light of the announced closing of the hospital.

Third year medical resident Thomas Sibert MD described their situation. He had:

just started his third year as an internal medicine resident at Hahnemann. Now, instead of focusing on finding a fellowship, he must simultaneously find another residency as well.

‘The people we are counting on for recommendations are themselves also looking for jobs,’ he told Medscape Medical News. ‘The attendings have been endlessly supportive. They’ve been working for the fellows at the same time they’re working for their residents interested in fellowships and looking for their own jobs.’

He described some of the worries the residents are facing.

Many have signed full-year leases for housing and some landlords have been unwilling to break them, he said. Because the areas near Philadelphia can only at this point — depending upon pending solutions — take a percentage of the displaced, others will need to move across the country and some states will require getting a new medical license with potentially months of background checks.

The consequences are especially severe for interns, Sibert said.

‘They are going to enter their new hospitals with very little clinical exposure because the number of patients and the resources at Hahnemann have been so severely reduced,’ he said.

A few days later, on July 15, a Philadelphia Inquirer article revealed another threat to some of the house staff:

Fifty-five Hahnemann University Hospital residents holding J-1 visas face the possibility of deportation if they cannot secure a position in an accredited program within 30 days of the hospital’s closure.

The visas enable foreign physicians to come to the U.S. for training at accredited medical schools.

The Solution: Sell the Residency?

The current and final owners of Hahnemann had a solution, of sorts.  The Philadelphia Business Journal reported their plan as of July 10, 2019, was to sell the residency program.

Hahnemann University Hospital and Tower Health said Wednesday they have entered into a letter of intent to transfer the majority of the residency and fellowship programs at Hahnemann/Drexel University to Tower Health.

Under the letter of intent, Tower Health will assume the responsibility for the continued training of the more than 550 residents and fellows in these programs — while giving those physicians-in-training the right to be placed in one of Tower Health’s six hospitals.


Tower Health said it will seek to hire the faculty who are currently training the residents and fellows to ensure continuity of the Hahnemann and Drexel training programs.

The July 15, Inquirer article noted that it really was a sale, not a “transfer,”

Tower Health has offered $7.5 million to buy Hahnemann’s 500-plus residency and fellowship slots, as well as the hospital’s Medicare ID number, which dictates the number of medical residents for which the hospital can receive federal funding.

However, that article also suggested that this plan might need some work. To begin, Tower Health had no structure to take on the complexity of the Hahnemann program:

But Tower has only eight accredited programs — significantly fewer than the 35 programs currently operating at Hahnemann, according to a court filing in the Hahnemann bankruptcy case. That’s a problem for many residents, but especially for those with J-1 visas.

‘We are very concerned about them,’ said Jaime Sanders, an anesthesiologist at Hahnemann. Under the terms of their visa, they cannot have any ‘gaps’ in their program, which will end when the hospital closes. Closure is slated for September.

Another question was would Tower have the faculty to teach and supervise the residents? On July 18, 2019, an Inquirer article noted that a lot of the Drexel University faculty who were involved in the Hahnemann residency program were slated to lose their jobs:

About 40 percent of Drexel University physicians and clinical staff will lose their jobs as a result of the planned closure of Hahnemann University Hospital, Drexel president John Fry announced in an email to the university staff Thursday morning.

Tower Health was supposed to take on some of them, but the details were unclear.

Fry said that Tower Health Medical Group will become the college’s new partner and will be able to offer approximately 60 percent of the 800 clinical faculty and staff within the program employment in their current jobs. Tower also expects to be able to offer about half of the remaining 40 percent comparable positions at similar pay at Tower locations in Reading, Chestnut Hill, and the Philadelphia suburbs, said Jill Tillman, CEO and associate dean of Drexel University Physicians.

The 800 clinical faculty and staff include 245 physicians who received severance notices on Thursday, though many of them will be offered employment through Tower, Tillman said. Tower has offered to keep all primary care physicians, she said, minimizing disruption to patients.

And again, where exactly would these faculty fit in at Tower Health?

that six-hospital system does not have all the accredited training programs it would need to accommodate Hahnemann’s 500-plus residents. The plan is also subject to approval by U.S. Bankruptcy Court, which has scheduled a hearing for Friday.

Drexel plans to eliminate certain health-care service lines as a result of the closure, Fry said.

In a separate email to staff on Thursday, Drexel senior vice president for medical affairs Daniel V. Schidlow provided some details about which medical services Tower would seek to retain. Family medicine and internal medicine, including primary care, would continue in their current Drexel Medicine practice locations. Tower wants to meet with physicians and clinical staff in emergency medicine, surgery, cardiology, and other specialties ‘about employment opportunities’ within Tower’s system.

Tower’s Chestnut Hill Hospital — its only property in Philadelphia — does not have a maternity unit, but Schidlow said Drexel’s obstetricians and midwives may be offered jobs within the Tower system.

Many of the residents were totally unconvinced that this plan would work, or that it had their interests at heart.  A Bloomberg article on July 19, 2019, described their plea to the bankruptcy judge,

The bankruptcy sale of Hahnemann University Hospital’s education program is treating more than 570 doctors as financial assets and threatening their ability to complete the final stage of their specialized medical training, a group of hospital residents told a judge overseeing the case.

About 20 hospital residents, most wearing medical coats bearing the Drexel University College of Medicine logo, asked U.S. Bankruptcy Court Judge Kevin Gross to force the hospital’s owner Philadelphia Academic Health Systems LLC to guarantee the doctors have continued access to the federal Medicare money that pays their salaries.

‘The residents of Hahnemann are not assets,’ said Dr. Raluca McCallum, a resident who spoke from a prepared statement in court on behalf of her colleagues. McCallum said the residents have continued to provide the highest level of patient care possible ‘for Philadelphia’s sickest, poorest and most downtrodden population.’

Nonetheless, the judge seemed willing to use a market approach to decide the house staff’s fate:

Gross gave the company permission to set up a potential auction for the residency program with an initial bid of $7.5 million from Tower Health, a health care company that owns hospitals in the region. They are an owner of hospitals and related medical facilities in the area.

Today, the Inquirer just reported that Tower did not win the bidding war for the residents and their program.

Hahnemann University Hospital’s residency slots fetched a $55 million winning bid from team of six local health systems at Thursday’s bankruptcy auction, topping bids by Tower Health and a California company that wants to reopen the Center City hospital.

Christiana Care Health System, Cooper University Health Care, and Main Line Health joined Einstein Healthcare Network, Jefferson Health, and Temple University Health System in the winning bid

This begs the question of how one could run a residency program currently populated by house staff based in Philadelphia that is split among six large hospital systems spread from Delaware to New Jersey.  Organizing something like that would be a huge, perhaps unprecedented undertaking.

Would former Hahnemann residents now shuttled around to destinations including multiple hospitals in six systems and three states feel even more like assets, or widgets?  As the man says, we shall see.

Was an Asset Sale the Plan All Along?

Given that Hahnemann had been placed under the tender protections of a for-profit hospital corporation along time ago, after it ended the abusive relationship with the failed AHERF (look here),  maybe it should not have been a big surprise that the finale would be asset sales.

An opinion piece in Bloomberg contained observations by Prof Alan Sager of the Boston University School of Public Health, including:

Hahnemann has posted operational losses every year from 2004 to 2018, a ‘remarkable’ record, said Sager, who reviewed public documents kept by Pennsylvania on hospital finances.

Yet despite sustaining such apparent “losses” for 14 years, Tenet seemed to not be interested in trying to turn the hospital around.  An article in the Inquirer from July 20, 2019, featured an interview with the president of Drexel University, whose medical school was tied to Hahnemann.  It stated,

When John Fry became president of Drexel University in 2010, he inherited a medical school that was hobbled by its relationship with Hahnemann Hospital, where aspiring doctors got hands-on training.

Serving mostly poor Philadelphians, the historic facility was struggling financially. Important maintenance kept on being put off, he said, and there was only ‘passive interest’ from the hospital’s for-profit owner, Tenet Healthcare Corp.

‘We wanted a first-rate place to educate our students and treat our patients,’ Fry said in an interview Thursday, “and we never had that.”

Why would Tenet continue to own and operate a hospital that lost money for 14 straight years without making any apparent effort to improve the situation?  In my humble opinion, there is only one explanation that makes sense.  The losses were an illusion, product of an accounting trick.  Tenet was extracting money from the hospital, possibly in the guise of administration/ management expenses charged to Hahnemann, as if the hospital was a stand-alone entity, not a subsidiary of Tenet.  Those charges led to a sham analysis that showed chronic deficits.  When Tenet got tired of stripping assets, or the assets available for stripping were drying up, it was time to sell.

After Paladin Healthcare, a private equity firm bought the hospital, asset sales were clearly in the cards.  A CBS News article featuring an interview with a disillusioned Hahnemann nurse recited what we already know about how private equity works, in health care as well as elsewhere. It included a discussion by an expert on private equity who explained why these firms are now so interested in health care:

The expectation that health care will provide a sure return in volatile economic times, said Eileen Appelbaum, co-director of the Center for Economic and Policy Research and an expert on private equity.

‘Health care is a major area of investment for private equity,’ Appelbaum said. ‘They look at health care the way they used to look at supermarkets. They said, ‘People have to eat, so this is safe investment.’ Now they are saying that about health care.’

However, the private equity playbook may spell doom for the health care organizations such firms acquire:

Private equity funds acquire companies that are struggling or distressed yet still have value. PE executives then direct management to make operational changes in order to boost a business’ performance. The goal is to turn around the businesses and eventually sell them for a profit.

But private equity firms also tend to raise money by issuing debt from their target company, which critics say can make it tougher for a struggling company to make a recovery. In the worst cases, critics say, fragile businesses can be pushed into insolvency by their new debt burdens.

The reason Tenet bought Hahnemann after the AHERF bankruptcy, and the reason Paladin was willing to buy the hospital from Tenet may have been all about the value of the real estate involved, not the health care or medical education the hospital provided.

But in Hahnemann’s case, economist Appelbaum said, it appears the hospital was bought for the value of its real estate, not for its mission to provide care to low-income Philadelphians. The hospital is located near a burgeoning arts district in central Philadelphia, as well as Temple University, which makes the land valuable to developers.

‘It’s the first time I know for a hospital being bought by a private equity company in what appears to be a pure real estate play,’ she said.

Again, the article highlighted the steps that neither Tenet nor Paladin took that might have kept the financially ailing hospital – if indeed it was – afloat.

To make Hahnemann a financially viable hospital, its management could have taken several steps, such as buying hospitals in wealthier, suburban neighborhoods, which would have diversified its revenue. It could have also opened smaller, urgent care clinics, which are increasingly popular with patients, she said.

“They did none of those things,” she said. ‘Surprise, surprise, the hospital tumbled more and more into the red, then 18 months later they went to bankruptcy.’

In any case, in the private equity model, once the decision was made to declare bankruptcy, the residency program became just another, and relatively inconsequential asset to be sold.  The residents, and faculty, like the patients, were just subjects of collateral damage.Why shouldn’t they all be outraged?

Graduate Medical Education Adrift in a Sea of Commercialized Health Care

In 2007, Dr Arnold Relman wrote(1) that physicians’ core values are threatened:

are the ethical foundations of medicine, including the commitment of
physicians to put the needs of patients ahead of personal gain, to deal
with patients honestly, competently, and compassionately, and to avoid
conflicts of interest that could undermine public trust in the altruism
of medicine.

These threats arose from “the growing commercialization of the US health care system.”
This has been abetted by physicians who accept “the view that medical
practice is also in essence a business.” Thus, “the vast amount of money
in the US medical care system and the manifold opportunities for
physicians to earn high incomes have made it almost impossible for many
to function as true fiduciaries for patients.”

Since 2007, nothing has stopped the march to an ever more commercially focused US health care (non-)system.  Meanwhile, the mission of taking the best care of each patient, and thus necessarily providing adequate education to health care professionals, fades into the rear view mirror.

Although the original argument for the commercialization of health care came from neoliberalism, (or market fundamentalism) especially in its dogma that:

harshly reinstated the regulatory role of the market in all aspects of
economic activity and led directly to the generalisation of the
standards and practices of management from the private to the public
sectors. The radical cost cutting and privatisation of social services
that followed the adoption of neoliberal principles became a public
policy strategy rigorously embraced by governments around the world(2)

 Yet, as Prof Sager pointed out in the Bloomberg article,

‘This is a symptom of the underlying anarchy that pervades U.S. healthcare,’ Alan Sager, a professor of health law, policy and management at the Boston University School of Public Health, said referring to the plan to shut Hahnemann. ‘Nobody is accountable for identifying the hospitals that are needed for the public. There is no free market and there is no government accountability.’

Neoliberalism may seem like a lot of economic mumbo jumbo, but ask the patients and staff of the former Hahnemann University Medical Center, and the house staff and faculty of its former residency program about its impact.

If only we could go back to a time when hospitals were non-profit community and/or academic institutions, when for-profit hospitals and the commercial practice of medicine was banned, when anti-trust laws were enforced to prevent ever growing corporations from enforcing ever growing power.  If only…

Such drastic changes, however, would all greatly threaten those who have become wealthy off the current system.  Think of the former CEO of AHERF, the current CEO of Tenet, the owner of Paladin Healthcare, and indirectly, all those plutocrats and oligarchs out there.

However, unless the public is willing to discomfit these plutocrats and oligarchs, what happened to Hahnemann and its residency program will likely soon seem like a trivial problem compared to what will come next. 


1. Relman AS. Medical professionalism in a commercialized health care market. JAMA 2007; 298: 2668-2670. [link here]

2.  Komesaroff PA, Kerridge IH, Isaacs D, Brooks PM.  The scourge of
managerialism and the Royal Australasian College of Physicians.  Med J
Aust 2015; 202: 519- 521.  Link here.