Comments on CON Regulations and Legislator Involvement Needed TODAY
Friday, June 27, 2014 10:03 AM
On June 1, the Office of Health Policy published proposed changes to 900 KAR 6.070 Certificate of Need (CON) Considerations for Formal Review. Comments will be accepted through June 30. The proposed change would eliminate the need criteria, which is separate and distinct from criteria in the State Health Plan. Adoption of these changes would significantly change the CON program in Kentucky and would result in the unneeded proliferation of health care services because an application that complies with the State Health Plan would be presumed as meeting the “need” criteria even if the State Health Plan methodology is outdated or inaccurate.
Every KHA member should submit comments outlining concerns with these regulations to the Cabinet on or before Monday, June 30. Hospitals can submit their own comments or you may say that you support the comments submitted by KHA. It is also important to get legislators involved in this issue. KHA is particularly interested in getting support of the Regulation Review Committee and getting Republican legislators to contact Senate Leadership on the issue. KHA’s comments are available here.
Please Take the Following Actions:
- Submit comments by June 30 from your hospital directly to the Cabinet and explain the negative consequences on your hospital if the CON process was relaxed and new facilities could easily establish in your area (see examples in KHA’s comment letter). If this is not possible, please submit a comment letter in support of KHA’s comments and recommendations.
- Share the Talking Points (available here) with your state legislators and ask them to contact Secretary Audrey Haynes or Deputy Secretary Eric Friedlander IMMEDIATELY to express their concerns with the proposed regulations.
- Urge your Republican legislators to contact the Senate Leadership office directly regarding the problems with the proposed regulation.
- If your legislator serves on the Regulation Review Subcommittee (list available here), contact them with the talking points and ask them to contact the Cabinet with their opposition to the regulation.
Please share information about your legislator discussions with KHA. Direct comments and reports to Elizabeth Cobb at KHA (502-426-6220 or 800-945-4542 or via email at email@example.com).