North Carolina 2025 Draft State Medical Facilities Plan and Summer Petitions

The North Carolina State Health Coordinating Council (SHCC) has published its draft 2025 State Medical Facilities Plan (SMFP) and all summer petitions and comments have been received. This blog post will address:

• The SMFP process
• The assets available under the SMFP
• The petitions and comments submitted to the following SHCC subcommittees:
  • Acute Care Services
  • Long Term and Behavioral Health
  • Technology and Equipment

SMFP Process

The SMFP is a guiding document for healthcare planning in North Carolina and provides projections of need for CON-reviewable facilities and healthcare services. It summarizes supply and utilization for each facility and service, describes projection methods and policies, and provides other data relevant to need projections. Health care providers and facilities in North Carolina can only gain approval for additional assets that are published as needed in the SMFP.

The development of the SMFP is a continuous process that includes several opportunities for public comment. Two of these opportunities include a spring and summer petition period. The spring petition period is intended for requests regarding the SMFP that have potential for statewide effect, including requests for addition, deletion or revision of policies of methodology for determining need. The summer petition period is after the Agency has considered the spring petitions and published a Proposed SMFP in early July. Summer petitions involve requests for adjustments to the need determinations in the Proposed SMFP.  Members of the public can also submit general comments about need determinations during the summer petition period. Both spring and summer petitions/comments are published on the Agency website and given a two-week public comment period for others to respond to individual petitions. Each petition is assigned to its appropriate SHCC committee.

Services with a Published Need in the Draft 2025 SMFP

The table below summarizes the needs published in the Draft 2025 SMFP. As the table shows, there is a published need for acute care beds in nine service areas, five of which have a need for over 100 beds. There is also a need for operating rooms, several categories of major medical equipment, and adult care homes.

Summer Petitions and Comments Submitted

In total, seven petitions and two comments were submitted during the summer petition period. Below are brief summaries of each petition, organized under their applicable SHCC committee. Each summary includes a link to the petition, as well as a link to submitted comments, if applicable.

Acute Care Services Committee

Petitions

DLP Maria Parham Medical Center submitted a petition for the removal of 30 acute care beds from need determination in Vance/Warren counties. Their petition argues there is a special geographic issue in Vance County that has caused an excess of beds, inaccuracy in the growth rate multiplier and unnecessary duplication of resources. The petition argues access is not currently an issue in the service area and bringing another health system into the rural, economically fragile service area would jeopardize the existing hospital campuses. Two letters were submitted in support of their petition. No formal opposition was received.

Pender Memorial Hospital d/b/a Novant Health Pender Medical Center submitted a petition to remove the need for 43 acute care beds in Pender County. The petition states there was an error in the Hospital Industry Data Institute (HIDI) acute care days which caused an error in the resulting bed need projections. In Table 5A of the Proposed 2025 SMFP, non-acute care bed days were included in NH Pender’s HIDI data. The petition states that, once the error is corrected, there is no projected acute care bed need in Pender County. No letters of support or formal opposition were received for this petition.

Comments

AdventHealth Asheville submitted a comment in support of the need determination for 129 additional acute care beds in the Buncombe/Graham/Madison/Yancey service area that was published in the Draft SMFP. In Spring 2024, Agency staff developed and presented an alternative model for need determinations to the Acute Care Committee. This alternative model uses the most recent five years of facilities’ acute days of care in the growth rate multiplier, instead of using fiscal years 2015-2019 (pre-COVID pandemic years). AdventHealth Asheville argues the projected population growth and aging demographics of the service area support the need for 129 additional acute care beds which were calculated using the alternative model. No letters of support or formal opposition were received for this petition.

Cone Health submitted a comment in support of the need determination for 46 acute care bed need determination in Alamance County. The comments support the Agency’s alternative model for need determinations presented to the Acute Care Services Committee in Spring 2024. Cone Health argues tremendous growth in the Triad and the Triangle area has driven population growth in Alamance County, including net migration of individuals and families. No letters of support or formal opposition were received for this petition.

Long-Term and Behavioral Health Committee

Petitions

Gibson Care Corporation d/b/a Home Instead submitted a petition to create an adjusted need determination for a licensed home health agency in Iredell and/or Alexander County in the 2025 SMFP. The petition argues that aging seniors want to remain in their home due to long term care costs. The petition argues that another home health agency is needed to provide an affordable option for seniors while also decreasing hospital admissions/readmissions, improving medication management and administration, as well as control of pressure injuries. Two letters of support were submitted for this petition. Iredell Health System and Association for Home and Hospice Care of North Carolina submitted comments in opposition of this petition.

Heart’n Soul Hospice of the Carolinas submitted a petition for an additional home health care agency in Mecklenburg County. The petition argues there is an unfair advantage for existing providers to expand into a new county because they are able to do so without demonstration of need in the new service area. The petition also argues the need methodology should be updated to capture these expanded hospice licenses to accurately capture need. The petition provides data that show low penetration rates, underserved communities of color and high population growth. Forty-one letters of support were submitted for this project. Well Care Health, Association for Home and Hospice Care of North Carolina/North Carolina Healthcare Association, Carolina Caring and VIA Health Partners submitted comments in opposition of this petition. During the public hearing period, members of the SHCC committee requested additional data from Heart’n Soul  Hospice, as well as VIA Health Partners. This data has been published on the Agency’s website.

Technology and Equipment Committee

Petitions

Mission Hospital submitted a petition to convert HSA I’s general PET need determination to a specific need determination for one fixed cardiac PET scanner. The petition argues that, although heart disease is the leading cause of death in HSA I, it is the only HSA in North Carolina without a cardiac PET program. The petition argues that advances in PET cardiac imaging would be helpful in managing the health of cardiac patients. Mission Health also argues there is significant capacity and lack of significant future demand for oncology PET services in HSA I. Three letters of support were submitted for this petition. Margaret R. Pardee Memorial Hospital and Novant Health submitted comments in opposition of this petition.

Wayne Memorial Hospital, Inc., d/b/a UNC Health Wayne submitted a petition to create a special need adjustment for one additional linear accelerator in Wayne County for a provider of cancer care that does not currently have a linear accelerator. The petition argues that the aging population, racial makeup and high cancer incidence rate support the need for an additional linear accelerator. The petition notes that the only provider for radiation therapy in Wayne County is for-profit and is not a North Carolina-based healthcare system and the only radiation oncologist in the county is nearing retirement. The petition argues that these factors lead to a level of uncertainty about the long-term stability of current radiation therapy services in Wayne County. The petition discusses an internal analysis which shows there is a need for linear accelerator services for UNC Health Wayne patients. The specificity of the request of the petition is supported through references to two SHCC precedents. The first reference was the 2022 WakeMed petition for a special need determination for one additional linear accelerator in Service Area 20, which the SHCC approved. The second reference was the 2021 Carteret Health Care petition for adjusted need determination for one linear accelerator for a single county, which the SHCC approved. The petition also states that the Agency has also acknowledged this need through the creation of its Policy TE-4 in Spring 2024. No letters of support or formal opposition were received for this petition.

Catawba Valley Medical Center submitted a petition for an adjusted need determination for one additional unit of hospital-based fixed cardiac catheterization equipment in Catawba County. The petition argues that utilization statistics show the existing equipment at the facility is at capacity, but the need methodology did not produce need in the county because of equipment and usage at Frye Regional. The petition states that sending cardiologists and patients to Frye Regional is logistically challenging and puts unnecessary health and potential financial strain on their patients. Their petition refers to a SHCC precedent when UNC Rex was permitted a special need for one additional unit of fixed cardiac catheterization equipment in Wake County in 2016. No letters of support or formal opposition were received for this petition.

Looking Forward

After the public comments period, the Agency prepares a recommendation on whether to approve, deny or alter the need determination adjustment request. Agency reports are discussed at the next SHCC committee meetings where committee members vote to approve, deny or alter the Agency’s recommendations. The committees forward their recommendations to the SHCC. At their final meeting, the SHCC considers all information provided and completes their final recommendation of the 2025 SMFP. The recommended final 2025 SMFP is presented to the Governor who may approve it as recommended or make any adjustments or amendments they deem appropriate. The deadline for final Governor approval is December 31, 2024.

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