Oppose Universal Health Services Expansion of Psychiatric Services in Oregon

I

have serious economic, quality, and safety concerns related to the NEWCO Certificate of Need (CN) application to build a new psychiatric hospital in Wilsonville. Rather than patching a substantial problem with a second-rate soggy bandaid, Oregon officials should seek to create the resources actually needed, such as meaningful community level programs and access to supportive housing for those living with serious mental illness. Further, if acute psychiatric beds are needed, Universal Health Services (UHS), the parent corporation of NEWCO, is the worst possible option.

My opinions are based on my experience as a psychiatric registered nurse, a former plaintiff’s medical malpractice attorney, and also as a new psychiatric nurse practitioner who, in all likelihood, will need to seek inpatient care or other resources for my future patients.

UHS operates Cedar Hills Hospital in Beaverton. Upon moving here from the east coast I worked there. Though the clinical staff are nothing but wonderful, the business practices were very concerning, unethical, and contrary to compliance regulations. I eventually worked in the admissions department where I felt corporate directives violated the Emergency Medical Treatment and Labor Act (EMTALA). Essentially, they gave directives to cherry pick patients out of emergency rooms according to insurance status. The uninsured or OHP patients were only offered beds after all the insureds were placed, if at all. Choosing patients for admission on the basis of insurance status is a violation of the Medicare Conditions of Participation as related to EMTALA.

I filed an EMTALA complaint with CMS which resulted in Cedar Hills being placed on the Medicare termination track for the above described behavior. The findings of that investigation, along with other investigative findings can be found at Hospitalinspections.org.

This is a company that runs the majority of behavioral health facilities in the United States. Any suggestion they did not know this was a patent violation of compliance regulations is unreasonable and unlikely at the very minimum. My opinion is that this is a business strategy. Thus, I encourage any decisions made, be made with extreme caution.

When a hospital cherry picks insured patients out of emergency rooms, other hospitals suffer financial strain. Cherry picking is known as “reverse dumping” in the EMTALA world. Other hospital systems bear the brunt of these actions because they will be forced to care for the majority of unfunded or underfunded patients. Sadly, this process often leaves those who need help the most waiting the longest or without care altogether.

From a quality and safety standpoint, UHS was severely understaffed. I believe their staffing plan and administrative structure is woefully insufficient. As an example, a 25 bed unit may have two RNs, one LPN, and one or two “mental health techs” the educational requirement for which is a high school diploma or its equivalent. The providers often had outside practices and swing through to see patients. They may see as many as 20-25 because some may cover a full unit. The social workers did discharge planning and provided group therapy. This leaves little, if any, time to do either role well. The experience of administrators often begins with UHS so they don’t know best practices.

Compare UHS staffing to a hospital where a 25 bed unit has 6 RNs, including a free charge nurse, two behavioral health therapists, a position which requires a bachelors degree in a behavioral health field and two years of experience. The hospital has social workers who exclusively do discharge planning, and therapists of various types who coordinate and run group activities. The hospital has onsite lab and EKG capability, dietitians involved in care, physical therapy, and peer support. Further, the providers there have one job, and are limited to 7-9 patients a day in most circumstances. They are present throughout the day.

In this environment, patients have the best change at receiving appropriate care in a safe and therapeutic environment. As a nurse, I have the ability to know my patients well and I have the opportunity to meet their needs more days than not. In this environment, interdisciplinary team meetings focus on unique patient needs rather than number of days left for insurance to pay. This is the type of care we should strive for and the type of care you would want for your own family members.

In addition to habits of poor staffing and the provision of substandard care, UHS is a company that recently paid over 100 million dollars to settle Medicare fraud allegations. This is likely merely the the cost of doing business. If you search for this company on the Internet, you will find many instances of fraud allegations, patient harm and death, and other unsafe practices.

Until I became involved in opposing this initiative I did not know UHS’s massive roll in the teen residential industry. I believe the plan is to expand that into Oregon, as well. Many victims have spoken out against this corporation as a result of the abuse and neglect either they or their family members suffered at the hands of this organization. I challenge anyone involved in this decision to do their research.

We undoubtedly need viable solutions to the behavioral healthcare challenges we are facing. A UHS facility opens another revolving door, places financial resources in the wrong place, and puts good hospitals and patients in harms way. Perhaps we do need acute psychiatric beds. But take serious care when choosing who provides them. And also consider other areas for change such as length of commitment, lack of use of assisted outpatient treatment, lack of community resources and housing for those with serious mental illness, underutilized state hospital space, and failure to provide good mental health care in the correctional system.

As a psychiatric nurse, I see the same people over and over again in the acute inpatient setting. Some stay for months at a time. Yet upon discharge, nothing has been fixed and they nearly always return.

This CN is supposed to be about providing reasonable access to quality healthcare at a reasonable cost. There is nothing about granting this that moves the needle towards reaching that goal, nor will it improve Oregon’s standing as the worst in the nation. We are a small state. Allowing UHS to expand its book of business here can do tremendous harm to our mental health system as a whole and direct harm to those who have the misfortune of receiving services at a UHS facility.

Please submit public comments to oppose to PAM.L.KRECKLOW@dhsoha.state.or.us