The 23-page response includes a myriad of statistics, requested by former Health Commissioner John Dreyzehner, as well as details about how downgrading Holston Valley Medical Center’s NICU from a Level III to a Level I nursery will impact newborns and mothers in the region.
Under the plan, newborns requiring Level III NICU services will be transported to Niswonger Children’s Hospital in Johnson City. Ballad has estimated that roughly 100 babies per year, who would have previously received care at Holston Valley, will be transported to Niswonger Children’s Hospital under the proposal.
One specific detail the state requested in its latest line of questioning is how Ballad plans to track the travel distance of affected families.
“Tracking mileage is not a standard practice as the region is defined and can vary based on patient origination. Patient origination data is available, and demonstrates that more than 500 newborns were transferred to Niswonger from distances greater than one hour away ... and as much as two hours away,” Ballad Health CEO Alan Levine wrote in his response.
“Distances like this are not unusual for children's hospitals, and certainly, in Tennessee, fairly typical with respect to the regional perinatal centers, of which there are only five ...The vast majority of Level III NICU services are provided at Niswonger today, so the distances are not a new issue.”
Dreyzehner also questioned why Ballad Health waited until Nov. 12 to notify the state, since the NICU consolidation decision had apparently already been made as early as April 2018, according to an SEC filing regarding Ballad’s bond refinancing.
Levine said the proposed NICU consolidation, as well as the Level I Trauma consolidation, were cited throughout the Certificate of Public Advantage, or COPA, application process.
“Ballad also set forth a process to consider service eliminations or consolidations in the Master Affiliation Agreement and Plan of Integration, which was approved by the Department,” Levine wrote.
“The consolidation of the Trauma Centers and the Level III NICUs were opportunities identified as early as 2015 and discussed with the state during the application process. However, no decisions were made on the consolidation of the Level III NICUs until November of 2018.”
In addition to consolidating its Level III NICU services from two locations to one, Ballad also wants to implement a “Newborn Care Model,” which involves maintaining Level I nurseries at six locations.
On Nov. 12, Levine submitted an initial letter to the state requesting approval of the proposed changes to pediatric services, which also includes opening pediatric emergency rooms in Kingsport and Bristol and expanding telemedicine connectivity to Niswonger Children’s Hospital.
The Department of Health responded with a list of 14 questions, which Ballad Health answered on Dec. 28.
However, those answers were apparently not sufficient for the departing Dreyzehner, who was replaced by West Tennessee hospital executive Dr. Lisa Piercey in Gov. Bill Lee’s cabinet, prompting him to submit more more than a dozen more questions.
Under the COPA, which governs the Ballad hospital merger, state officials are required to to consider whether the pediatric changes proposed by Ballad will have any negative impact on access to health care services, quality of care or employees.
Once the state receives all the information it deems necessary to process the request for changes to pediatric services, a 90-day approval period will begin.
Read the latest letter from Ballad to the state.