Date: March 31, 2014
To: Governor's Policy Advisor
Subject: Recommendations for CON
Thank you for your request to participate in this important effort to provide recommendations regarding how CON policy should be revised for the state of Georgia in light of the Affordable Care Act. As it is understood, the purpose of the CON program is to ensure the availability of adequate healthcare services to meet the needs of all Georgians, while safeguarding against the unnecessary duplication of services that perpetuate the costs of health- care services. The basic premise was that hospitals competed on the basis of having the latest technology and the broadest range of services and not based on price. While increasing healthcare inflation and shortage of access are still affecting many Georgians, controlling healthcare costs and improving access to healthcare have received great attention. As a result, cost and access have become hot topics for policymakers. In addition, the landscape of healthcare is changeable in a significant way. First, I would like to address some CON shortcomings which interfere with CON goals regarding the Affordable Care Act and access to healthcare services. They are as follows:
CON is based more on institutional needs rather than public health needs. Also, decisions might be made in response to provider proposals for site facilities in a given area.
Priority consideration is not always given to needs identified in DCH plans.
The CON process is sometimes based on "first in-first out." As a result, a hospital seeking to expand primary care in under-served communities is delayed by a CON process that would not apply to a private practitioner seeking to establish the same service.
The current CON process delays the conversion of private practices to primary care clinics, so this delay is against the DCH goals of improving access to primary care with affordable cost.
The CON process with its rules tends to be lengthy, expensive, and reactive.
Some hospitals oppose CON applications to force applicants through an expensive legal battle to obtain the CON.
I strongly believe that the existing CON should be abolished. If Georgia were to admit more healthcare providers to infiltrate the market, costs would significantly decline. The elimination of CON can increase competition and more facilities can be opened to compete against the dinosaurs of healthcare. In addition,