Judges: K. N. AYERS
Agency: Agency for Health Care Administration
Latest Update: Apr. 17, 1986
Summary: Prior to establishing bed need methodology for ophthalmic ambulatory surgery centers, a non-rule policy followed. No new Certificate of Needs approved.
85-2443.PDFSTATE OF FLORIDA
DIVISION OF ADMINISTRATIVE HEARINGS
MEDIVISION OF ESCAMBIA COUNTY, ) INC., )
)
Petitioner, )
)
vs. ) Case No. 85-2443
)
DEPARTMENT OF HEALTH AND )
REHABILITATIVE SERVICES, )
)
Respondent, )
)
and )
) WEST FLORIDA REGIONAL MEDICAL ) CENTER, SACRED HEART HOSPITAL ) OF PENSACOLA and BAPTIST )
HOSPITAL, INC., )
)
Intervenors. )
)
RECOMMENDED ORDER
Pursuant to notice the Division of Administrative Hearings, by its duly designated Hearing Officer, K. N. Ayers, held a public hearing in the above styled cause on February 18 and 19, 1986, at Tallahassee, Florida.
APPEARANCES
For Petitioner: Robert A. Weiss, Esquire
Mabry Rainer, Esquire
118 North Gadsden Street, Suite 101 Tallahassee, Florida 32301
For Respondent: Theodore E. Mack, Esquire
1323 Winewood Boulevard,
Tallahassee, Florida 32301
For WFRMC: Thomas M. Beasom, Esquire
118 North Gadsden Street, Suite 100 Tallahassee, Florida 32301
For Baptist: F. Phillip Blank, Esquire
241 East Virginia Street Tallahassee, Florida 32301
For Sacred Heart: Karen O. Emmanuel, Esquire
Post Office Drawer 1271 Pensacola Florida 32596
By Petition for Formal Administrative Hearing dated June 14,1985, Medivision of Escambia County, Petitioner (Medivision), contests the denial of its application for a certificate of need to establish a two operating room opthalmic ambulatory surgery center in Escambia County, Florida. This case was initially consolidated with a similar application by Ameribealth Escambia County Ambulatory Surgery Center, Inc., but the latter withdrew its application leaving only this Petitioner. West Florida Regional Medical Center (WFRMC), Sacred Heart Hospital of Pensacola (Sacred Heart) and Baptist Hospital Inc. (Baptist), were all granted leave to intervene.
At the hearing the Department of Health and Rehabilitative Services reversed its initial position and, in these proceedings, supported the application. Petitioner called six witnesses, DHRS called one witness, WFRMC called one witness, Baptist called two witnesses, Sacred Heart, called three witnesses, and ten exhibits were admitted into evidence. Proposed findings submitted by the parties have been considered. Treatment accorded those proposed findings is contained in Exhibit A attached hereto and made a part hereof.
FINDINGS OF FACT
Medivision Escambia County, Inc. is a wholly owned subsidiary of Medivision, Inc. a corporation formed in 1984 to establish free standing opthalmic surgery centers.
Bain Capital Fund, a venture capital group, owns most of the stock in Medivision, supplies the equity capital and lends Medivision additional funds to establish the facilities. Medivision has, as of the date of this hearing, established nine
(9) free standing opthalmic outpatient surgery centers, with two in Florida. Bain has committed itself to provide more than
$500,000 in equity capital and more than $500,000 in long term debt to Petitioner needed to establish the proposed facility. Petitioner is financially capable of establishing the proposed facility.
The three intervening hospitals are located in Pensacola, Escambia County. WFRMC owns and operates a free standing outpatient surgery center with four designated
outpatient surgery suites, with one suite reserved for eye surgery. Sacred Heart owns and operates a free-standing outpatient surgery center which contains five surgery suites dedicated exclusively for outpatient procedures and Baptist has four operating suites dedicated solely to outpatient procedures.
DHRS issued its original notice of intent to deny Medivision's application on May 17,1985. On June 14,1985, Medivision timely filed its petition for formal administrative hearing (DOAH Case No. 85-2443). Thereafter, DHRS reconsidered its initial decision, and on February 14, 1986, DHRS notified all parties that it intended to grant Medivision's application.
This change of position by DHRS resulted from a change from an outpatient ratio of 30% of all surgeries will be performed as outpatient surgeries to 40% of all surgeries will be performed on an outpatient basis in the horizon year.
DHRS has not promulgated a rule upon which to base the need for freestanding ambulatory surgery centers. DHRS has, however, employed an evolving non-rule policy in evaluating the need for such facilities. The methodology employs the following steps:
Acquire data regarding the number of inpatient and outpatient procedures performed by existing providers
Using this data, calculate overall surgical use rate and outpatient surgical use rate for the service area;
Using the projected population for the horizon year (1989) and the current use rate, calculate projected number of surgeries;
Multiply total projected surgeries by 40% to establish total outpatient pool for horizon year;
Subtract from result obtained in (d), all out patient surgical procedures to be performed in hospitals and free standing ambulatory surgery centers;
Subtract financial break-evens of all certificates of need approved free standing outpatient surgery centers from this pool; and
After subtractions, the number of surgical procedures remaining are compared to the break-evens of certificate of need applicant at issue. If pool is larger than break-evens, a quantitative need is demonstrated. If pool is smaller than break- evens, the quantitative need is not demonstrated.
This non-rule methodology does not address the need for specialty ambulatory surgical centers such as an opthalmic outpatient surgical center.
Applying this methodology to Escambia County and using data from the last quarter of 1984 and the first three quarters of 1985 shows a total of 16,475 inpatient surgeries and 9,163 outpatient surgeries for a total of 25,638. Thus, 34.52 percent of all surgeries in Escambia County were outpatient. July 1985 population of Escambia County is estimated at 265,429. The surgical rate for Escambia County is 25,638 divided by 265,429 over 1000 or 96.59 surgeries per 1,000 population. The January 1989 projected population is 278,624. If this is multiplied by the surgical rate of 96.59 a total of 26,912 surgeries can be expected in 1989. Multiplying this total surgeries by 40% yields 10,765 outpatient surgeries in the horizon year for Escambia County. If the outpatient surgery use rate stays the same as present the outpatient surgeries in Escambia County in 1989 will be 34.52 x 278,624 over 1000 or 9618. Subtracting this from 10,765 projected outpatient procedures gives 1147 procedures available to be performed over and above the number presently performed. Under the methodology used these surgical procedures are available to show need for this applicant.
The break-even point for the second year of operation of the proposed Medivision facility is 722 procedures. Under the methodology as applied by DHRS the 1147 procedures available meets this break-even point.
This application involves the construction and operation of a facility to perform only eye surgeries. Opthalmic surgery procedures currently comprise approximately 26% of the total outpatient surgery procedures performed. Today nearly all eye surgeries are performed in an outpatient setting. Adding impetus to this trend the regulations require medicare payments. be limited to outpatient surgeries for opthalmic procedures performed on medicare patients unless for some specific reason the patient has other problems which require the availability of inpatient surgery room equipment when undergoing eye surgery.
On the other hand the ratio of outpatient surgeries to total surgeries has grown from less than 20 percent a few years ago to well over 30 percent today. When applications for freestanding ambulatory surgical facilities were first considered by DHRS the methodology developed used the estimate of 29 percent of all surgeries would be performed in the outpatient setting in the horizon year. This figure was increased to 30 percent in 1985 and DHRS recently increased this "outpatient" factor to 40 percent. The fact that 34.52 percent of the surgeries performed in Escambia County during the past year were performed in an outpatient netting attests to the validity of the 40 percent factor projected for 1989.
Each of the three hospitals which intervened in these proceedings have dedicated outpatient surgical programs; however, each is part of the outpatient department of its respective hospital. There are currently no free standing ambulatory surgery centers as defined in Sec. 381.493(3)(a) Florida Statutes in Escambia County, Florida. A previously established free standing ambulatory surgery center was purchased by Hospital Corporation of America and is now operated as a outpatient arm of West Florida Regional Medical Center.
Outpatient surgical procedures are less costly to the patient than are inpatient surgical procedures. To encourage greater use of such facilities and to reduce medical costs, HCFA, the federal agency administering medicare, since 1982, has reimbursed licensed freestanding ambulatory surgical facilities at a Fla. rate for the provision of such surgery, with no cost to the patient. For hospital based outpatient surgery HCFA reimbursement is based on the hospital's cost of providing the service. Of this cost HCFA reimburses 80 percent after the patient's deductible has been used. Because of these higher hospital based outpatient surgery costs, HCFA finds it less costly to pay the entire approved charge at a freestanding outpatient surgical facility than 80 percent of the cost at a hospital based outpatient surgical facility. Freestanding outpatient surgical facilities are-important in controlling the cost of medical care.
Upwards of 75 percent of all opthalmic surgical procedures are performed on persons aged 65 and over. Accordingly, Medivision projects that approximately 80 percent of the surgical services provided at its facility will be paid by medicare. Because of the payment procedures employed by HCFA all medicare patients have access to freestanding ambulatory surgical facilities and can have cataract surgery performed in such a facility at no cost to the patient.
On the other hand, if Medivision is to meet the procedures necessary to reach the break-even point in 1989 it will have to take patients who would otherwise go to the intervenors for eye surgery above and beyond those opthalmic surgeries included in the 1147 procedures that will be available. If 26 percent of outpatient surgeries are opthalmic, only 298 of the 1147 procedures will be opthalmic. The surgical procedures necessary to reach the break-even point, perforce, will have to come from opthalmic surgeries that would otherwise be performed at the other hospitals.
Within Escambia County there exists 13 surgery suites dedicated solely to outpatient surgical procedures. As- dedicated outpatient surgical suites, these operating suites provide like and similar services to those sought to be offered by Medivision. Testimony was unrebutted that each dedicated, suite is capable of performing an optimal 1200 surgical procedures per year. This is based on 4.8 procedures per day times 250 working days per year. Accordingly, these suites have the optimum capacity to perform a combined total of 15,600 outpatient surgical procedures per year. The maximum capacity is considerably higher. Dividing the number of outpatient procedures performed during the past year, 9163, by the capacity of these outpatient surgical suites, shows that these suites operated at 58.7 percent of optimal capacity during the past year. To provide for the additional 1147 procedures projected to 1989 these suites would have to operate at 69 percent of their combined optimal capacity. If scheduling is sufficiently constant and consistent these suites can be used to perform 15,600 outpatient surgeries per year. This produces an excess capacity of 4835 outpatient surgical procedures available in Escambia County in 1989. At 1200 procedures per operating room there would be a surplus of four outpatient operating rooms in Escambia County in 1989.
During 1985, 286 opthalmic outpatient surgeries were performed at Sacred Heart, 1,735 were performed at WFRMC, and 368 were performed at Baptist for a combined total of 2,389 procedures. If those procedures increase in direct proportion to the population between 1985 and 1989, 2,508 eye procedures are forecast for 1989. To reach its break-even goal of 722 procedures in 1989 Medivision will have to capture almost 30 percent of the available market. This would have a substantial adverse impact on the three intervenors as these 722 procedures will come from the surgery pool that would otherwise be performed in the 13 existing outpatient suites.
Proposed findings addressed need for special equipment, for research and educational facilities, availability of resources, management and quality of care, financial feasibility,
availability of health care alternatives, impact on existing facilities, and capital expenditure proposals. No evidence was presented of need for special equipment or for research and educational facilities. Accordingly, these criteria are not applicable to this application. Resources of both financial and professional services are available for the successful accomplishment of this project. If a need exists for the proposed facility it is financially feasible. Medivision has the resources and management to provide quality care. Testimony relating to the adequacy or inadequacy of the layout, staffing and equipment for the proposed facility is largely irrelevant.
Architectural plans must be prepared and submitted to DHRS office of Licensure and Certification for architectural approval before construction can begin. Those plans must meet all statutory requirements before approval may be granted. Staffing requirements of the office of Licensure and Certification must also be met.
Alternatives to the proposed services are currently supplied by the dedicated outpatient surgery suites at the intervening hospitals. Whether the economies and accessibility to more patients provided by a freestanding ambulatory surgical facility outweighs the adverse affects approval of this application will have on existing providers is the primary issue in these proceedings. This is an issue on which DHRS presented little, if any, evidence. If the policy of DHRS is to approve all applications for freestanding ambulatory surgical centers in counties which do not have such a facility, this policy was not clearly expressed by DHRS's sole witness.
The methodology employed by DHRS and by Medivision to determine number of available procedures in the horizon year is flawed, particularly in the area of equating a speciality freestanding ambulatory surgery center with a general freestanding ambulatory surgical center. The 1147 procedures need derived from the methodology is total outpatient proceduresnot opthalmic procedures. It is unrealistic to conclude an ambulatory surgical facility, limiting its admissions to opthalmic surgery which comprise 26 percent of all outpatient procedures will reach the break even-point of 722 procedures when the methodology shows an increase in only 1147 total outpatient surgical procedures for the horizon year. Twenty-six percent of 1147 is 298.
A second flaw in the methodology is in not considering the excess capacity of existing providers and the extent to which this excess capacity can serve the 1147 additional procedures projected for 1989. As noted in finding No. 16 above these additional procedures would bring the existing dedicated outpatient suites up to less than 70 percent of optimal use.
CONCLUSIONS OF LAW
The Division of Administrative Hearings has juris- diction over the parties to, and subject matter of, these proceedings.
Although DHRS has no promulgated rule establishing a methodology for determining need for freestanding ambulatory surgery centers, it has attempted on at least two occasions to promulgate such a rule. For both of these occasions the proposed rules were successfully challenged and declared invalid. The same methodology is still used by DHRS as a non-rule policy, except that the 29 percent factor used in 1983 has been increased to 40 percent. This non-rule policy must be defended by the agency each time it is challenged. McDonald v Banking and Finance, 346 So. 2d 569 (F1a. 1st DCA 1977). This is a heavy burden, the policy carries with it no presumption of validity, and the need and authority for the policy must be sufficiently explained for agency review. Barker v Board of Medical Examiners, 428 So. 2d 720 (F1a. 1st DCA 1983).( Need for the proposed facility must be based on a balanced consideration of all statutory and rule criteria. Department of Health and Rehabilitative Services v Johnson and Johnson, 444 So. 2d 361,363 (F1a. 1st DCA, 1984). Petitioner here meets all of the statutory criteria with the exception of need and financial feasibility and these two are inextricably joined. A finding of need carries with it a finding that the proposed facility is financially feasible and vice versa.
Freestanding ambulatory surgery centers are favored because of their ability to reduce medical costs by increasing competition. This favoritism is recognized by HCFA in the reimbursement it makes for medicare patients.
On the other hand there are 13 dedicated outpatient surgical suites in Escambia County which have sufficient excess capacity to easily provide for the increase in outpatient surgical procedures forecast for 1989.
Insufficient evidence was presented to conclude that the need for additional competition that would result from the granting of this CON outweighs the adverse effect this would have on existing providers. This is particularly true where a specialty freestanding ambulatory surgical facility is involved and the need methodology used shows only the need for all outpatient surgeries. In order to be financially feasible in 1989 and meet its break-even point of 722 procedures Medivision would have to capture approximately 30 percent of the total opthalmic surgery market in Escambia County. The evidence
presented fails to show Petitioner capable of doing that. The burden is on Petitioner to show, by a preponderance of the evidence, that it is entitled to the CON sought. Balino v DHRS
348 So 2d 349 (F1 1st DCA 1977). This Petitioner has failed to do.
It is recommended that the application of Medivision of Escambia County, Inc. for a certificate of need to establish a two operating room opthalmic ambulatory surgical center in Escambia County be denied.
Entered this 17th day of April, 1986 at Tallahassee, Florida.
K. N. AYERS, Hearing Officer Division of Administrative Hearings The Oakland Building
2009 Apalachee Parkway
Tallahassee, Florida 32399
(904) 488-9675
Filed with the Clerk of the Division of Administrative Hearings this 17th day of April, 1986.
COPIES FURNISHED:
Douglas L. Mannheimer, Esquire Post Office Drawer 11300 Tallahassee, Florida 32302
Donna H. Stinson, Esquire The Perkins House, Suite 100
118 North Gadsden Street Tallahasee, Florida 32301
Karen O. Emmanuel, Esquire Post Office Drawer 1271 Pensacola, Florida 32596
Robert A. Weiss, Esquire
The Perkins House, Suite 101
118 North Gadaden Street Tallahassee, Florida 32301
Frank R. Olsavsky, Esquire 9100 South Dadeland Boulevard Suite 1200
Miami, Florida 33156
David P. Gaudlin, Esquire Department of HRS
1323 Winewood Boulevard
Tallahassee, Florida 32301
F. Philip Blank, Esquire Reynold Meyer, Esquire
241 East Virginia Street Tallahassee, Florida 32301
APPENDIX
TREATMENT ACCORDED PROPOSED FINDINGS OF FACT
I. Proposed findings of Medivision and DHRS
Included in HO # 1.
Accepted insofar as included in HO # 13.
Included in HO # 2.
Included in HO #6.
Included in HO #5.
Accepted insofar as included in HO #11.
Included in HO 8 and 9.
Included in HO 3 and 10 and 12, 13, and 14.
Rejected insofar as inconsistent with HO #16.
Accepted insofar as included in HO #2.
Accepted. Not deemed relevant to results reached.
Accepted insofar as included in HO #18.
Included in HO #2.
Accepted. Not deemed relevant to results reached.-
Included in HO #2.
Rejected as inconsistent with HO #14 and 15.
Rejected as inconsistent with HO #15,16, and 17.
Rejected as inconsistent with HO #15,16, and 17.
Accepted. Not relevant to results reached.
Accepted only insofar as included in HO #19.
Included in HO #13, 14.
Included in HO #18.
Accepted. Not relevant to results reached.
Rejected insofar as inconsistent with HO #l3.
Included in HO #21.
Included in HO #15.
Included in HO #15, 16, 19, and 20.
PROPOSED FINDINGS WFRMC
Included in preliminary portion of RO.
Accepted insofar as included in HO 42.
Rejected as irrelevant.
Rejected as irrelevant.
Rejected as irrelevant.
Included in preliminary portion of RO.
Included in HO #6.
Included in HO #6.
Accepted insofar as not in conflict with HO #8.
Rejected as irrelevant.
Rejected as stating a negative.
Accepted insofar as in agreement with HO #8.
Accepted.
Included in HO #20.
Included in HO #21.
Included in HO $17.
Accepted.
Included in HO #8.
Accepted.
Accepted insofar as included in HO #13.
Included in Ho #21.
Included in HO #16.
Included in HO #16.
Included in HO #16.
APPENDIX
JOINT PROPOSED FINDINGS OF BAPTIST HOSPITAL AND SACRED HEART HOSPITAL
Accepted. Relevant portions are included in HO #1.
Included in HO #4.
Included in HO #3.
Included in HO #3.
Included in HO #3.
Included in HO #6.
Included in HO #8.
Included in HO #7.
Included in HO #8.
Included in HO #10.
Included in HO #10.
Accepted insofar as included in HO #15.
Accepted insofar as included in HO #12 and 16.
Accepted insofar as included in HO #16.
Rejected as conclusion of law
Included in HO #18.
Included in HO #18.
Included in HO # 2.
Rejected as not relevant.
Included in HO #2.
Included in HO #18.
Accepted insofar as included in HO #8,9, and 15.
Accepted insofar as included in HO #17.
Included in HO #18.
Accepted insofar as included in HO #16.
Accepted. Not included because irrelevant and immaterial.
Figures rejected as speculative.
Accepted insofar as included in HO #17.
Accepted insofar as included in HO #17.
Rejected as inconsistent with HO #18.
Rejected as conclusion of law.
Rejected. Non-rule policy not applicable to specialty ambulatory surgery centers.
================================================================= AGENCY FINAL ORDER
=================================================================
STATE OF FLORIDA
DEPARTMENT OF HEALTH AND REHABILITATIVE SERVICES
MEDIVISION OF ESCAMBIA COUNTY, INC.,
Petitioner,
vs.
DEPARTMENT OF HEALTH AND
REHABILITATIVE SERVICES, CASE NO. 85-2443
Respondent,
and
WEST FLORIDA REGIONAL MEDICAL CENTER, SACRED HEART HOSPITAL OF PENSACOLA and BAPTIST HOSPITAL, INC.
/
FINAL ORDER
This cause came on before me for the purpose of issuing a final agency order. 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. Exceptions to the Recommended Order were filed by Petitioner.
RULING ON EXCEPTIONS
Exception number 1 is granted for the reasons given in the findings of fact where DHRS rejects the hearing officer's finding in paragraph 7 of the recommended order.
Exceptions number 2, 3 and 5 are denied as the hearing officer's findings are supported by substantial competent evidence.
Exception number 4 is denied in that it is not HRS policy to invariably grant a CON on the basis of any single factor or criteria. The grant or denial of a CON is based on a weighing of all statutory, rule and policy criteria.
Exception number 6 is denied in that the hearing officer's order does weigh the statutory and regulatory criteria in reaching his conclusion.
FINDINGS OF FACT
The findings of fact contained in the recommended order are hereby adopted and incorporated by reference except for the following. DHRS rejects the hearing officer's conclusion in paragraphs 7 and 20 that the DHRS non-rule need methodology does not address the need for an ambulatory surgery center applicant who proposes to provide only one type of surgery. Such a conclusion is in reality an opinion infused with policy insight for which DHRS has special responsibility McDonald v. Dent. Of Banking and Finance, 346 So. 2d 569 at 579 (Fla. 1st DCA 1977). Even though not every ambulatory surgical center may offer the full range of outpatient surgical services it is nevertheless appropriate to use a general need methodology as one factor to be weighed with the other statutory criteria in reviewing an application which proposes to provide only one surgery service such as ophthalmic services. The record supports a finding that ophthalmic services may be provided as a specialty, or as one of several of ambulatory surgical services. Under such circumstances it is appropriate to apply the DHRS need methodology. Otherwise an applicant could avoid review under the methodology by proposing to provide something less than all surgery procedures that can be done on an outpatient basis. DHRS witness Jaffe testified that the non-rule methodology has been applied consistently by DHRS in its evaluation of all applications for certificate of need to establish ambulatory surgical centers including Medivision's application.
Where a need is indicated under the methodology but there is also substantial excess capacity at the existing providers, the weight accorded to the need finding is diminished. Capital expenditure where there is already substantial excess capacity at existing providers is ultimately likely to result in increased cost to the consumer of medical services.
CONCLUSIONS OF LAW
The Department hereby adopts and incorporates by reference the conclusions of law set forth in the Recommended Order.
Based upon the foregoing, it is ADJUDGED, that the application of Medivision of Escambia County, Inc., for a certificate of need to establish a two operating room opthalmic ambulatory surgery center in Escambia County is denied.
DONE and ORDERED this 9th day of July, 1986, in Tallahassee, Florida.
WILLIAM J. PAGE
Secretary
A PARTY WHO IS ADVERSELY AFFECTED BY THIS FINAL ORDER IS ENTITLED TO JUDICIAL REVIEW WHICH SHALL BE INSTITUTED BY FILING ONE COPY OF A NOTICE OF APPEAL WITH THE AGENCY CLERK OF 'HRS, AND A SECOND COPY, ALONG WITH FILING FEE AS PRESCRIBED BY LAW, WITH THE DISTRICT COURT OF APPEAL IN THE APPELLATE DISTRICT WHERE THE AGENCY MAINTAINS ITS HEADQUARTERS OR WHERE A PARTY RESIDES. REVIEW PROCEEDINGS SHALL BE CONDUCTED IN ACCORDANCE WITH THE FLORIDA APPELLATE RULES. THE NOTICE OF APPEAL MUST BE FILED WITHIN 30 DAYS OF RENDITION OF THE ORDER TO BE REVIEWED
COPIES FURNISHED TO:
K. N. Ayers Hearing Officer
Division of Administrative Hearings Oakland Building
2009 Apalachee Parkway
Tallahassee, Florida 32301
Douglas L. Mannheimer, Esquire Post Office Drawer 11300 Tallahassee, Florida 32302
Donna H. Stinson, Esquire The Perkins House
118 North Gadsden Street Tallahassee, Florida 32301
Karen O. Emmanuel, Esquire Post Office Drawer 1271 Pensacola, Florida 32596
Robert A. Weiss, Esquire The Perkins House
118 North Gadsden Street Tallahassee, Florida 32301
Frank R. Olsavsky, Esquire 9100 South Dadeland Blvd. Suite 1200
Miami, Florida 33156
F. Phillip Blank, Esquire Reynold Meyer, Esquire
241 East Virginia Street Tallahassee, Florida 32301
Nell Mitchem, PDCFM
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing was sent to the above-named people by U. S. Mail this 14 day of July, 1986.
R. S. Power, Agency Clerk Assistant General Counsel Department of Health and
Rehabilitative Services 1323 Winewood Boulevard Building One, Room 407 Tallahassee, Florida 32301 904/488-2381
Docket for Case No: 85-002443
Orders for Case No: 85-002443
| Issue Date |
Document |
Summary |
|
Jul. 09, 1986 |
Agency Final Order
|
|
|
Apr. 17, 1986 |
Recommended Order
|
Prior to establishing bed need methodology for ophthalmic ambulatory surgery centers, a non-rule policy followed. No new Certificate of Needs approved.
|
