View PDF Version here.
The “post moratorium era” continues for the Nursing Home Certificate of Need (“CON”), with twenty-eight Letters of Intent filed in response to published Fixed Need Pools for an additional 493 nursing home beds statewide. Since the lifting of the moratorium on nursing home CON by the Legislature last year, the Agency for Health Care Administration (“AHCA “) has approved a total of 3,198 needed nursing home beds. Under the legislation, AHCA cannot approve any more CONs for nursing home beds equal to or greater than 3,750 (until June 30, 2017). Assuming AHCA awards all of the published need to these applicants, the total approvals by AHCA since the legislation was passed will be 3,691 beds. This would mean that there would only be 59 beds left before the 3,750 statutory cap is reached. Other deadlines are fast approaching, as well. Any provider that wishes to file a competing Grace Period Letter of Intent has until May 6, 2015 to file for a competing proposal.
The following tables show the Fixed Need Pool in each subdistrict where AHCA has received one or more letters of intent. The tables reflect the number of beds published in the Fixed Need Pool and a summary of the Letters of Intent received in each subdistrict to date. Additional notations are made as to any observations regarding the number of beds sought in relation to the fixed need pool.
(Escambia and Santa Rosa)
Need: 61
| Escambia | FL HUD Pensacola/Specialty Health and Rehabilitation Center | Add 30 community nursing home beds |
| Escambia | NF Bay, LLC | Establish a new 90-bed community nursing home |
| Escambia | PruittHealth – Escambia County, LLC | Establish a new community nursing home of up to 120 beds |
*Note: Two applicants have filed for a number greater than published need; and one less.
(Gadsden, Holmes, Jackson and Washington)
Need: 41
No LOIs received despite published need.
(Columbia, Hamilton and Suwannee)
Need: 113
| Columbia | MF Orange, LLC | Establish a new 113-bed community nursing home |
| Columbia | Palm Garden of Lake City, LLC | Establish a new community nursing home of up to 113 beds |
| Columbia | PruittHealth – Alachua County, LLC | Establish a new community nursing home of up to 113 beds |
| Columbia | Terrace Enterprises, LLC | Establish a new community nursing home of up to 113 beds |
(Alachua, Bradford, Dixie, Gilchrist, Lafeyette, Union, and Levy)
Need: 47
| Alachua | Innovative Medical Management Solutions, LLC | Establish a new 47-bed community nursing home |
| Alachua | Oak Hammock at the University of Florida | Add 17 community nursing home beds through the conversion of 17 sheltered nursing home beds |
| Alachua | Palm Garden of Gainesville, LLC | Add up to 47 community nursing home beds |
(Putnam)
Need: 34
| Putnam | Crestwood Nursing Center, Inc. | Add up to 34 community nursing home beds |
| Putnam | Lakewood Nursing Center, Inc. | Add up to 34 community nursing home beds |
(Marion)
Need: 0
| Marion | Ocala SNF, LLC | Establish a new community nursing home of up to 120 beds |
*Note: No published need, but an LOI was received.
(Citrus)
Need: 23
Need published but no LOIs filed.
(Hernando)
Need: 5
Need published but no LOIs filed.
(Nassau and North Duval)
Need: 14
| Duval | Edgewood Nursing Center, Inc. | Add up to 14 community nursing home beds |
| Duval | Innovative Medical Management Solutions, LLC | Establish a new 14-bed community nursing home |
(St. Johns and Southeast Duval)
Need: 0
| St. Johns | Saint Johns SNF LLC | Establish a new community nursing home of up to 120 beds |
*Note: No published need, but an LOI was received.
(Pasco)
Note: 44
| Pasco | Innovative Medical Management Solutions, LLC | Establish a new 44-bed community nursing home |
| Pasco | LP New Port Richey, LLC/Southern Pines Healthcare Center | Add 44 community nursing home beds |
(Highlands)
Need: 11
Need published but no LOIs filed.
(Orange)
Need: 0
| Orange | Orange SNF, LLC | Establish a new community nursing home of up to 120 beds |
*Note: No published need, but an LOI was received.
(Seminole)
Need: 33
| Seminole | Innovative Medical Management Solutions, LLC | Establish a new 33-bed community nursing home |
| Seminole | Lifespace Communities, Inc./Village on the Green | Add up to 33 community nursing home beds |
| Seminole | Seminole SNF LLC | Establish a new community nursing home of up to 120 beds |
*One applicant exceeds published need.
(Collier)
Need: 0
| Collier | Pelican Bay Retirement Services/Premier Place at the Glenview | Add up to 14 community nursing home beds through the conversion of up to 14 sheltered beds |
*Note: No published need, but an LOI was received.
(Indian River)
Need: 9
| Indian River | Palm Garden of Vero Beach, LLC | Add up to nine community nursing home beds |
(Martin)
Need: 9
Need published but no LOIs filed.
(Okeechobee)
Need: 4
Need published but no LOIs filed.
(Miami Dade)
45
| Miami Dade | CC-Aventura, Inc./VI at Aventura | Add up to 40 community nursing home beds |
| Miami Dade | Florida Medical Systems, LLC/Florida Medical Systems, LLC | Add up to 45 community nursing home beds and a partial of 15 beds |
| Miami Dade | Palm Garden of Aventura, LLC/Palm Garden of Aventura, LLC | Add up to 45 community nursing home beds |
| Miami Dade | Pediatric Specialty Care of Florida, LLC/Pediatric Specialty Care of Florida, LLC | Establish a new community nusing home of up to 45 beds |
Any provider that has been contemplating an opportunity to seek a CON for a new facility or additional beds at an existing facility should review the currently filed Letters of Intent carefully, and decide if now is the time to seek approval for a competing project. Existing providers should also carefully consider their options, and decide whether to oppose a project that may have a negative impact on existing operations. Please feel free to call me for any additional information.
Geoffrey D. Smith is a shareholder in the law firm of Smith & Associates, and has practiced in the area of health care law and CON regulation for over 20 years.
View PDF Version here.