STATE OF FLORIDA
DIVISION OF ADMINISTRATIVE HEARINGS
HOLMES HEALTH CARE, INC., )
)
Petitioner, )
)
vs. ) CASE NO. 84-0258
) DEPARTMENT OF HEALTH AND ) REHABILITATIVE SERVICES, )
)
Respondent. )
)
RECOMMENDED ORDER
For Petitioner: Bonnie K. Roberts, Esquire
Bonifay, Florida
For Respondent: Theodore E. Mack, Esquire
Tallahassee, Florida
A final hearing was held in this case in Bonifay on April 17, 1984. The issue is whether respondent Department of Health and Rehabilitative Services (Department) should grant the application of petitioner Holmes Health Care, Inc. (Petitioner), for issuance of a Certificate of Need (CON) for a $1,181,684 capital expenditure to add 60 nursing home beds in Holmes County. By stipulation, the parties have further narrowed the issue to involve consideration of only the criteria set forth in sections 381.494(6)(c)1, 2, 8, and 9, Florida Statutes (1983)--i.e., generally, need and financial feasibility.
FINDINGS OF FACT 1/
Background
Applicant, Holmes Health Care, Inc. (Petitioner), is a corporation formed for the purpose of constructing and operating a nursing home in Bonifay, Holmes County. Petitioner was organized on March 23, 1983, by Cody Taylor, Mr. Jewel E. Speed, Mrs. Lelah G. Wagner Speed, W. Shouppe Howell, Gertrude M. Lee, and Kenneth Robert Yates. Mrs. Speed has operated Bonifay Nursing Home in Bonifay, Holmes County, since 1959, more recently as principal of Lelah G. Wagner, Inc., d/b/a Bonifay Nursing Home. Mrs. Speed also has extensive experience in the operation of a nursing home and retirement center in Panama City. She is a registered nurse. Mr. Speed also has had extensive experience as business manager for the nursing home in Panama City and has operated the Bonifay Nursing Home with his wife for the past two to three years. Bonifay Nursing Home has enjoyed an excellent reputation for superior care under the Speeds' direction.
In order to facilitate accomplishment of Petitioner's goals, Mrs. Speed agreed to sell the existing facility in which her corporation was doing business as Bonifay Nursing Home and adjacent land to Petitioner for operation of a nursing home and construction of new nursing home facilities. In furtherance of this plan, Petitioner applied for and received from the Department an application for a Certificate of Need for 24 nursing home beds in Holmes County.
The Department issued to Petitioner the CON for 24 nursing home beds upon Petitioner's representation that it would proceed with construction of a new 60-bed nursing home facility on the premises under the combined authority of the 24-bed CON and the 36-nursing-home-bed CON under which Bonifay Nursing Home currently is operating. Mr. and Mrs. Speed would operate the new nursing home. Petitioner also made reference to plans to soon construct facilities to house an additional 60 nursing home beds at its facility.
Construction of the new 60-bed nursing home facility is scheduled to be completed during summer 1984. Upon completion, the sale of the former Bonifay Nursing Home facility and land from Lelah G. Wagner, Inc., to Petitioner will close.
This case involves Petitioner's application to construct the planned addition to add 60 nursing home beds to the 60-bed facility now nearing completion.
Need
The percentage of elderly living in poverty in the Department's service District II (which includes Holmes County) according to the latest available
U.S. census, is 27.41 percent. (Thirty-seven percent of the general population is under the poverty level.) The Percentage of elderly living in poverty in Florida, according to the latest available U.S. census, is 12.7 percent. The population age 65 and older projected three years into the future residing in District II, based on the latest mid-range projections published by the Bureau of Economics and Business Research at the University of Florida, is 54,676. The number of existing and approved community nursing home beds within District II (including both the 36 beds licensed to the Bonifay Nursing Home and the 24-bed CON recently issued to Petitioner) is 2,531.
The population age 65 and older projected three years into the future residing in Holmes County, based on latest mid-range projections published by the Bureau of Economics and Business Research at the University of Florida, is 2,382. The number of existing and approved community nursing home beds within Holmes County is 60 (consisting of the beds licensed to Bonifay Nursing Home, and the additional beds that have been approved for Petitioner).
The average patient census during the most recent six-month period for which the Department has available data is 31.2.
As previously mentioned, Bonifay Nursing Home was licensed as a 36-bed community nursing home. However, since licensure, federal regulations governing eligibility for Medicaid reimbursement have required nursing homes to afford at least 100 square feet of room floor space per patient. Accordingly, for Medicaid reimbursement Purposes, Bonifay Nursing Home was recertified as a 28- bed facility. In order to maintain its eligibility for Medicaid reimbursement, Bonifay Nursing Home was required to gradually reduce its patient population so that eventually no room would house two Medicaid patients.
Desiring to continue to be eligible for Medicaid reimbursement, Bonifay Nursing Home complied with the requirements and gradually reduced its patient population from 36 to 30. During this time, Bonifay Nursing Home was able to fill virtually all beds available consistent with the program of reduction.
When Petitioner's new nursing home facility is completed and becomes operational (projected to be during summer 1984) , all 60 beds will meet the requirements for eligibility for Medicaid reimbursement. Since December 1982, Petitioner has had a total of 161 contacts from different prospective patients seeking admission to the new 60-bed facility when construction is completed.
An overall shortage of community nursing home facilities in District II is reflected in the occasional need to place patients residing within the district in nursing homes outside the district much more frequently, patients residing or having strong family contacts in Holmes County must be placed in nursing homes outside Holmes County. According to records of Holmes County and the Department, as of April 1984, 54 of 70 Holmes County residents (77 percent) are in nursing homes outside Holmes County. The evidence suggests that the percentage of Holmes County residents placed in nursing homes outside Holmes County has been as high as 85 percent in the recent past. Many of these patients have to be placed as far away from Holmes County as Tallahassee and Pensacola.
As previously mentioned, there currently are 36 licensed and 24 approved community nursing home beds in Holmes County. In Jackson County, 231 beds are licensed and 69 have been approved. In Washington County, there are
120 licensed beds; and in Gadsden County there are 60 licensed beds and 120 approved beds.
A rational approach to prioritizing projects to add community nursing home beds within those four counties would be to review and rank the proposed projects under the following criteria (from Petitioner's Exhibit 6):
Priority #1 Proposals projecting to provide the best possible care, most cost efficiently, will receive priority over all other proposals.
Priority #2 Proposals for Counties within Sub-districts indicating the greatest additional "Need' when applying the District ration [sic3 will receive priority over proposals for Counties within Sub-districts indicating the least additional need when applying the District ratio.
Priority #3 Proposals for Counties with Sub-districts experiencing the highest percentage of occupancy will receive priority over proposals for Counties within Sub-districts experiencing the least percentage of occupancy.
Priority [sic] #4 Proposals for Counties within Sub-districts with the greatest percent of population aged 65 and over living in poverty will receive priority over proposals for Counties with Sub- districts with the least percentage of population aged 65 and over living in poverty.
Priority #5 Proposals for Counties within Sub-districts with the greatest percentage of the aged population being served by home health care services, day care [sic] for the aged, home chore services, and adult congregate living facilities will receive priority over
proposals for Counties within Sub-districts providing the four service areas to the least percentage of the aged population.
Priority #6 Proposals for nursing home CONs agreeing to provide services for the greatest percent of Medicaid patients will receive priority over those proposals agreeing to provide none or the least percentage of Medicaid patients.
Priority #7 Proposals for Counties within Sub-districts with no outstanding nursing home certificate(s) of need beds will receive priority over Counties
within Sub-districts [sic] with outstanding nursing home certificate(s) of need beds.
Priority #8 All other proposals.
Applying those criteria, Petitioner's proposed project in Holmes County would have priority at this time over any projects that might be proposed in Washington, Jackson, or Gadsden County.
Financial Feasibility
Petitioner has a firm commitment from the City of Bonifay, as issuer, and First United Securities Group of California, as underwriter, to finance well in excess of the estimated $1,181,684 construction cost for the proposed 60-bed addition through the issuance of first mortgage industrial development revenue bonds. The bonds would be issued in accordance with a Resolution of the City of Bonifay adopted March 28, 1983, to issue up to $4 million of first mortgage industrial development revenue bonds for the purpose of assisting Petitioner in the financing of the acquisition, equipping, and construction of a nursing home facility in Bonifay having up to 120 skilled and/or immediate care beds. Of the
$4 million, $1,590,000 of bonds, Series 1983, already have been issued (and were sold before they were printed). The bond agreement of sale for the $1,590,000 issuance authorizes the construction of additional buildings and improvements on
the land, and the final bond offering statement contemplates the issuance of additional bonds ranking on a parity with the Series 1983 bonds to pay the cost of expanding the nursing home project to include an additional 60 beds.
Although certain conditions must be met before the additional bonds can be issued under the same indenture agreement securing payment of the initial bond issuance, there is no reason to believe the conditions could not be met.
Therefore, financing for construction of the 60-bed addition is feasible.
Debt service on an additional $1,181,684 proposed construction, at the maximum interest rate of 13.5 percent, would be $159,527 for the year ending March 31, 1985. With other operating expenses, Petitioner could break even on the cost of operating the additional 60 beds with a 76 percent occupancy rate including 74 percent Medicaid patients reimbursed at $44.73 per day. If the reimbursement rate is increased to $52 per day for Medicaid patients, just a 67 percent occupancy rate would be needed to break even during the year ending March 31, 1985. A 76 percent occupancy rate is feasible, and higher occupancy rates can be expected in subsequent years.
CONCLUSIONS OF LAW
Two general legal issues are involved in this case: need and financial feasibility. Need is the subject of c
Section 381.494(6)(c)1 and 2, Florida Statutes (1983); financial feasibility is the subject of Section 381.494(6)(c)8 and 9, Florida Statutes (1983).
Need
Sections 381.494(6)(c)1 and 2 provide:
The need for the health care facilities and services and hospices being proposed
in relation to the applicable district
plan and state health plan adopted pursuant to Title XV of the Public Health Service Act, except in emergency circumstances which pose a threat to the public health.
The availability, quality of care, efficiency, appropriateness, accessibility, extent of utilization, and adequacy of like and existing health care services and hospices in the service district of
the applicant.
The Department has also promulgated Rules 10-5.11(2) and (3), Florida Administrative Code, on the subject of need:
The relationship of health services proposed to the long-range development plan of the person providing or proposing such health services.
(3)(a) The need that the population served or to be served has for the health or hospice services proposed to be offered or changed, and the extent to which all residents
of the district, and in particular low income persons, racial and ethnic minorities, women, handicapped persons,
other underserved groups and the elderly, are likely to have access to those services.
The extent to which that need will be met adequately under a proposed reduction, elimination or relocation of a service, under a proposed substantial change in admissions policies or practices, or by alternative arrangements, and the effect of the proposed change on the ability of members of medically underserved groups which have traditionally experienced difficulties in obtaining equal access to health services to obtain needed healthcare.
The contribution of the proposed service in meeting the health needs of members of such medically underserved groups, particularly those needs identified
in the applicable local health plan and State health plan as deserving of priority.
In determining the extent to which a proposed service will be accessible, the following will be considered:
The extent to which medically underserved individuals currently use the applicant's services, as a proportion of the medically underserved population in
the applicant's proposed service area(s),
and the extent to which medically underserved individuals are expected to use the proposed services, if approved;
The performance of the applicant in meeting any applicable Federal regulations requiring uncompensated care, community service, or access by minorities and handicapped persons to programs receiving Federal financial assistance, including
the existence of any civil rights access complaints against the applicant;
The extent to which Medicare, Medicaid and medically indigent patients are served by the applicant; and
The extent to which the applicant offers a range of means by which a person will have access to its services.
In any case where it is determined that an approved project does not satisfy the criteria specified in subparagraphs (3)(a) through (d), the Department may,
if it approves the application, impose the condition that the applicant must take affirmative steps to meet those criteria.
In evaluating the accessibility of a proposed project, the accessibility of the current facility as a whole must be taken into consideration. If the proposed project is disapproved because it fails to
meet the need and access criteria specified herein, the Department will so state in its written findings. In any case where a project does not satisfy the criteria specified in subparagraphs (3)(a) through
(d) above, the Department shall so notify in writing the applicant and the appropriate Regional Office of the United States Department of Health and Human Services.
As to 381.494(6)(c)2, a shortage of community nursing home beds in Holmes County requires resident patients to be placed in nursing homes outside Holmes County 75 to 85 percent of the time. Often such patients must be placed as far away as Tallahassee and Pensacola.
As to Rule 10-5.11(2), the 60 beds Petitioner proposes to add to its new facility under construction are in accord with Petitioner's long-range development plans.
As to Rule 10-511(3)(a), the proposed addition will help serve the general local population, including poor and minorities. One problem addressed by the Petitioner's proposal (and by its currently approved new facility) is the square footage of room floor space needed to serve and be reimbursed for Medicaid patients. Petitioner estimates that 70 to 75 percent of its patients will be Medicaid patients. Finally, Holmes County's percentage of elderly poor is over twice the state average, and 37 percent of its general population is under the poverty level. All these factors, taken together, suggest that the general local population will be served.
As to Rule 10-5.11(3)(b), the evidence shows that some of the shortage of patient beds in Holmes County is due to the excellent reputation of Bonifay Nursing Home for superior care. As a result of its reputation, patients from as far away as Miami and Texas seek admission. It is conceivable that an admissions policy change restricting admissions of patients from outside Holmes County or District II would help alleviate the local bed shortage. But nothing in the statutes or rules suggests that such an admissions policy change should be encouraged; Section 381.494(6)(c) 11 and Rule 10-5.11(9) suggest the contrary.
Subsections (3)(c) through (f) of Rule 10-5.11 either already have been addressed, are not pertinent, or are addressed by Rule 10-5.11(21).
Rule 10-5.11(21) sets forth a methodology which normally controls the question of need for new or additional community nursing home beds in a district or subdistrict. Subsection (b) of the rule provides for district need determination:
(b) Need Methodology. In addition to relevant statutory criteria and applicable rule criteria to be used in considering need for new or additional community
nursing home beds, the Department will determine if there is a projected need for new or additional community nursing home beds three years into the future according to the following methodology:
De
N = --- x R X R - E
Se b
Where:
N is area-specific allocation of community nursing home beds for the calendar year for which a projection is being made,
De is the percentage of elderly living in poverty in the relevant departmental service districts according to the latest available U.S. census,
Se is the percentage of elderly living in poverty in the State according to the latest available U.S. census,
R is the statewide bed need ratio (27 community nursing home beds per 1,000 population age 65 years and older)
P is the population age 65 and older projected three years into the future residing in the relevant departmental district based on latest mid-range projections published by the Bureau of Economics and Business Research at the University of Florida, and
E is the number of existing and approved b community nursing home beds within the
relevant departmental service district.
26. In this case, De 27.41 and Se 12.70; P 54,676; and E b = 2,531.
Therefore,
(27.41 27
N = ----- x ----- x 54,676) - 2,531 657 = 657
(12.70 1,000
Subsection (21)(c) of the rule provides that subdistrict need for Holmes County is determined in the same manner as is district need under (b). Since P for Holmes County is 2,382 and E(b) is 60,
N (58.3 X 2382) - 60 = 79
(1,000)
Subsection (d) of the rule then provides for a calculation of the current utilization of licensed nursing home capacity:
(d) Current Utilization. Consideration of additional nursing home beds within a district will be based both upon need as determined in subsections (b) and (c) of
this rule and the extent of current uti lization relevant to licensed community nursing home bed capacity, determined as follows:
Uc = PC
Lb
Where:
Uc is current utilization of community nursing home beds.
PC is the average patient census during the most recent six month period for which the Department has data available.
Lb is the current number of licensed community nursing home beds.
In this case, PC for Holmes County = 31.2 and Lb = 36, resulting in a Uc of 86.7 percent. But in fact, of the beds actually available under Bonifay Nursing Home's program to reduce patient population to meet Medicaid requirements, 100 percent were utilized.
Under Subsections (e) and (f) of the rule, the methodology sets an 85 percent current utilization threshold, which is now exceeded in Holmes County (86.7 percent versus 85 percent).
Since the threshold is met, the methodology proceeds to Subsection (g) of the rule, which provides for calculation of prospective utilization:
(g) Prospective Utilization. When the appropriate current utilization threshold [sic] is satisfied, and assuming other relevant standards and criteria are met, additional beds may be added up to the point at which further bed additions would cause prospective utilization (Up) for the sub-district to drop below the prospective base rates specified in (h).
Prospective utilization will be determined as follows:
Up PC = PC (Eb + Pb)
Where:
Up is prospective utilization of community nursing home beds.
PC is the average patient census within the area during the most recent six month period prior to the filing of the CON application(s) under considera tion for which the Department has data available.
Eb is the current number of licensed and approved commu nity nursing home beds within the area.
Pb is the number of additional beds being proposed.
In this case, PC for Holmes County is 31, Eb is 60, and Pb is 60. Therefore,
U = 31 = 25.8 percent
p 120
Since only 31 beds actually were available under Bonifay Nursing Home's program of reduction, a more rational approach would be to set Eb at 55 Then,
U = 31 = 26.9 percent
p 115
In either case, Subsection (h) of the rule establishes the prospective base rate of utilization for Holmes County as 80 percent (the lowest base rate)
Under the rule methodology, as interpreted by the Department, this means that Petitioner's proposed 60-bed addition is not needed at this time. The most beds that could be added under the methodology would be two to three.
It is apparent that the methodology does not make sense when the need determined under it greatly exceeds the number of existing and approved beds. Ironically, under a strict application of the methodology, the greater the need, the longer the area in need must wait for the need to be met. For example, in this case, Holmes County needs 79 additional beds in 1986. But no applicant would be able to add more than two to three beds at this time. /2 As the Department grants successive applications, gradually Petitioner will be able to add more and more beds under the methodology. But it would be long after 1986 before Holmes County gets the 79 additional beds which the methodology reveals will be needed in 1986.
The evidence shows that there may be enough prospective patients already seeking admission to fill the 60 licensed and approved to immediately fill them and fill 80 percent of the additional 60 beds sought in this application. The evidence is even stronger that there will be enough prospective patients to fill 80 percent of a 120-bed facility by the time the proposed 60-bed addition is complete. This is further proof of the present need to certify the proposed 60-bed addition and to the inappropriateness of the methodology under the particular facts of this case.
By its own terms, more than just the Rule 10-5.11(21) need methodology must be considered in determining whether new or additional beds should be certified. See Department of Health and Rehabilitative Services v. Johnson and Johnson Home Health Care, Inc., 447 So.2d 361 (Fla. 1st DCA 1984). Indeed, even if the rule and statute do not require consideration of other criteria, under proper circumstances, the Department can and should, by entry of final orders on a case-by-case basis in 120.57 cases, deviate from its rules as necessary to reach a more rational. result. See, e.g., E. M. Watkins & Co., Inc. v. Bd. of Regents, 414 So.2d 583 (Fla. 1st DCA 1982). Such an approach is indicated by the competent substantial evidence in this case. Accordingly, notwithstanding the strict need methodology of Rule 10-5.11(21), there is a need for the 60 additional beds for which Petitioner applies in this case.
Financial Feasibility
Sections 281.494(6)(c)8 and 9, Florida Statutes (1983), provide:
The availability of resources, includ- ing health manpower, management personnel, and funds for capital and operating expenditures, for project accomplishment
and operation; the effects the project will have on clinical needs of health pro- fessional training programs in the service district; the extent to which the services will be accessible to schools for health professions in the service district for training purposes if such services are available in a limited number of facil- ities; the availability of alternative uses of such resources for the provision of other health services; and the extent to which the proposed services will be accessible to all residents of the ser- vice district.
The immediate and long-term financial feasibility of the proposal.
The only pertinent legal issues raised by the evidence are: (1) whether Petitioner has available the "funds for capital and operating expenditures, for project accomplishment and operation"; and (2) the "immediate and long-term financial feasibility of the proposal." In this case, the proposal meets both criteria.
Petitioner has a firm commitment from the City of Bonifay, as issuer, and First United Securities Group of California, as underwriter, to finance well in excess of the $1,181,684 estimated construction cost for the proposal through the issuance of first mortgage industrial development revenue bonds. The financing appears feasible.
As to payment of debt service and other operating costs of the additional 60 beds, Petitioner should be able to break even with between 67 and
75 percent occupancy, depending on the Medicaid reimbursement rate. This is a reasonable expectation under the facts of this case.
Based on the foregoing Findings of Fact and Conclusions of Law, it is recommended that the Department issue to petitioner Holmes Health Care, Inc., a Certificate of Need for 60 additional community nursing home beds in an addition, to be constructed, to its 60-bed facility now under construction, with permission to use the existing Bonifay Nursing Home facility under the CON until the 60-bed addition is constructed.
RECOMMENDED this 8th day of June, 1984, in Tallahassee, Florida.
J. LAWRENCE JOHNSTON Hearing Officer
Division of Administrative Hearings The OAKLAND Building
2009 Apalachee Parkway
Tallahassee, Florida 32301
(904) 488-9675
Filed with the Clerk of the Division of Administrative Hearings this 8th day of June, 1984.
ENDNOTES
/1 All proposed findings of fact submitted by the parties after the final hearing have been considered and rejected in favor of these findings of fact.
/2 No other applicant could be expected to apply for a CON for a new facility if only two to three beds could be approved under the methodology. If one does, the proposal or proposals almost certainly would be terribly duplicative and cost-inefficient.
COPIES FURNISHED:
Bonnie K. Roberts, Esquire Post Office Box 667 Bonifay, Florida 32425
Theodore E. Mack, Esquire Department of Health and Rehabilitative Services 1323 Winewood Boulevard
Building 1, Suite 407
Tallahassee, Florida 32301
Mr. David H. Pingree Secretary
Department of Health and Rehabilitative Services 1323 Winewood Boulevard
Tallahassee, Florida 32301
=================================================================
AGENCY FINAL ORDER
=================================================================
STATE OF FLORIDA
DEPARTMENT OF HEALTH AND REHABILITATIVE SERVICES
HOLMES HEALTH CARE, INC.,
Petitioner,
vs. CASE NO. 84-0258
DEPARTMENT OF HEALTH AND REHABILITATIVE SERVICES,
Respondent.
/
FINAL ORDER
This cause came on before me for the purpose of issuing a final agency order. On June 8, 1984, the Hearing Officer assigned by the Division of Administrative Hearings (DOAH) in the above-styled case submitted a Recommended Order to the Department of Health and Rehabilitative Services (HRS). A copy of that Recommended Order is attached hereto.
PDCF meaning the HRS Office of Community Medical Facilities filed Exceptions to
the Recommended Order. A copy of PDCF's Exceptions is attached hereto as Exhibit A.
HRS STATEMENT AND RULING ON THE EXCEPTIONS
(AA) PDCF Exceptions (1), (5), (6), (7), (8), and (9)- The prospective utilization figure must be at least 80 percent. These Exceptions make it clear that the figure calculated by the Hearing Officer himself is 26.9 percent. It is error for the Hearing Officer to discard this portion of the approved methodology. The particular circumstances of the sub-district and District, i.e., the apparent need, are certainly worthy of consideration. But, considering the addition of 24 beds to the Petitioner's already existing 36, the noted circumstances do not justify deviating from the approved methodology.
Petitioner's increase from 36 to 60 is appropriate. An increase from 36 to 120 is inappropriate; it requires a deviation from the approved methodology! The Exceptions are sustained.
(AA) PDCF Exceptions (2) and (3) These Exceptions are sustained.
Petitioner's increase from 36 to 60 beds and the construction of a more spacious facility address the problems.
(AA) PDCF Exception (4) Sustained.
(AA) PDCF Exception (10) Since the prospective utilization percentage (Up) is only 26.9, HRS must reject the recommendation to approve the 60 beds under dispute in this case. The Exception is sustained.
FINDINGS OF FACT
The Department hereby adopts the findings of fact made by the Hearing Officer but with the significant modification set out and explained in PDCF's Exception (1).
CONCLUSIONS OF LAW
The overall recommendation submitted by the Hearing Officer is rejected.
The recommendation is based upon an erroneous or otherwise inappropriate interpretation and application of law. The correct interpretation and application, which compels a different result, is set out in the HRS Statement and Ruling on PDCF's Exceptions. Accordingly,
It is ADJUDGED that the application of Holmes Health Care, Inc., for a Certificate of Need to add 60 community nursing home beds to its 60-bed facility now under construction is DENIED.
ORDERED this 23 day of July, 1984, in Tallahassee, Florida.
DAVID H. PINGRE
Secretary
COPIES FURNISHED:
Bonnie K. Roberts, Esquire Post Office Box 667 Bonifay, Florida 32425
Theodore E. Mack, Esquire 1323 Winewood Boulevard
Tallahassee, Florida 32301
J. Lawrence Johnston, Hearing Officer Division of Administrative Hearings The Oakland Building
2009 Apalachee Parkway
Tallahassee, Florida 32301
Harden King, Agency Clerk Department of HRS
1323 Winewood Boulevard
Suite 407
Tallahassee, Florida 32301
| Issue Date | Proceedings |
|---|---|
| Jul. 23, 1984 | Final Order filed. |
| Jun. 08, 1984 | Recommended Order sent out. CASE CLOSED. |
| Issue Date | Document | Summary |
|---|---|---|
| Jul. 23, 1984 | Agency Final Order | |
| Jun. 08, 1984 | Recommended Order | No need for nursing home beds under rule method, but rule doesn't work when raw need is great. Other factors warrant grant. Final Order: reversed based on rule. |
