Encompass Health Home Health of Alabama, LLC Kindred at Home, LLC Amedisys Home Health and LHC Group, Inc. v. State Health Planning and Development Agency, Madison Home Health Services, LLC, and ProHealth Home Health, LLC

CourtCourt of Civil Appeals of Alabama
DecidedFebruary 10, 2023
DocketCL-2022-0539
StatusPublished

This text of Encompass Health Home Health of Alabama, LLC Kindred at Home, LLC Amedisys Home Health and LHC Group, Inc. v. State Health Planning and Development Agency, Madison Home Health Services, LLC, and ProHealth Home Health, LLC (Encompass Health Home Health of Alabama, LLC Kindred at Home, LLC Amedisys Home Health and LHC Group, Inc. v. State Health Planning and Development Agency, Madison Home Health Services, LLC, and ProHealth Home Health, LLC) is published on Counsel Stack Legal Research, covering Court of Civil Appeals of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Encompass Health Home Health of Alabama, LLC Kindred at Home, LLC Amedisys Home Health and LHC Group, Inc. v. State Health Planning and Development Agency, Madison Home Health Services, LLC, and ProHealth Home Health, LLC, (Ala. Ct. App. 2023).

Opinion

Rel: February 10, 2023

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is published in Southern Reporter.

ALABAMA COURT OF CIVIL APPEALS OCTOBER TERM, 2022-2023 _________________________

CL-2022-0538 _________________________

Encompass Health Home Health of Alabama, LLC; Kindred at Home, LLC; Amedisys Home Health; and LHC Group, Inc.

v.

State Health Planning and Development Agency, Madison Home Health Services, LLC, and ProHealth Home Health, LLC

Appeal from the Certificate of Need Review Board of the State Health Planning and Development Agency (AL2021-21)

_________________________

CL-2022-0539 _________________________

Encompass Health Home Health of Alabama, LLC; Kindred at Home, LLC; Amedisys Home Health; and LHC Group, Inc. CL-2022-0538; CL-2022-0539

State Health Planning and Development Agency, Madison Home Health Services, LLC, and ProHealth Home Health, LLC

Appeal from the Certificate of Need Review Board of the State Health Planning and Development Agency (AL2021-24)

FRIDY, Judge.

In these consolidated appeals, Encompass Health Home Health of

Alabama, LLC; Kindred at Home, LLC; Amedisys Home Health; and

LHC Group, Inc. (collectively "the Intervenors"), appeal from a decision

of the Certificate of Need Review Board ("the CONRB") of the State

Health Planning and Development Agency ("SHPDA") issued in

proceedings it had designated as Project No. AL2021-21 ("the Madison

Project") and Project No. AL2021-24 ("the ProHealth Project"). The

CONRB's decision in the Madison project granted the application of

Madison Home Health Services, LLC ("Madison"), for a certificate of need

("CON") authorizing it to establish a home-health agency to provide

home-health services in Madison County. The CONRB's decision in the

ProHealth project granted the application of ProHealth Home Health,

LLC ("ProHealth"), for a CON authorizing it to establish a home-health

2 CL-2022-0538; CL-2022-0539

agency to provide home-health services in Madison County.1 For the

reasons discussed herein, we affirm the CONRB's decisions to grant both

the CON application of Madison and the CON application of ProHealth.

Background

In 2021, Madison and ProHealth each filed an application with

SHPDA for a CON authorizing it to establish a home-health agency to

provide home-health services in Madison County. 2 SHPDA "batched"

Madison's and ProHealth's applications. 3 Thereafter, the Intervenors, all

of which were already providing home-health services in Madison

County, intervened in the SHPDA proceedings regarding Madison's and

ProHealth's applications to oppose those applications and requested a

contested-case hearing. SHPDA appointed attorney Mark Waggoner as

1Section 22-21-275(6), Ala. Code 1975, authorizes direct appeals to this court from final decisions of SHPDA.

2Caring Hearts Home Care, LLC ("Caring Hearts"), also filed an application for a CON authorizing it to establish a home-health agency to provide home-health services in Madison County in 2021; however, Caring Hearts subsequently withdrew its application.

3"Batching is the formal review in the same 90-day review cycle and comparative consideration of all completed applications pertaining to similar types of services, facilities, or equipment affecting the same health service area." Ala. Admin. Code (SHPDA), r. 410-1-7-.19(1). 3 CL-2022-0538; CL-2022-0539

the administrative-law judge ("ALJ") to conduct the contested-case

hearing. The ALJ held a four-day contested-case hearing regarding both

applications in September 2021.

On January 24, 2022, the ALJ issued a seventy-two-page

recommended order in which he made proposed findings of fact and

proposed conclusions of law; he also recommended that the CONRB grant

the CON applications of both Madison and ProHealth. In pertinent part,

the ALJ's recommended order stated:

"31. The undersigned ALJ has determined that, provided the CON review criteria are satisfied by both parties, there is adequate legal authority to approve both the Madison Project and the ProHealth Project, without any legal limitations requiring the grant of only one CON home health application in any given batching cycle.

"32. As an initial matter, the 2020-2023 Alabama State Health Plan, Ala. Admin Code § 410-2-1 et. seq. ('SHP') governs the Projects. The SHP is drafted by the State Health Coordinating Council ('SHCC') based on population and utilization data provided by the SHPDA Division of Data Management. Based on information provided by the SHPDA Division of Data Management, the SHP shows a need for an additional 964 patients to be served in Madison County -- the largest need shown in the entire state. (Madison Ex. 67). The Madison Project aims to treat 131 patients in year one and 364 patients in year two. (Madison Ex. 1). The ProHealth Project aims to treat 200 patients in year one and 450 patients in year two. (ProHealth Ex 1). Adding these two projections together, the projection of patients to be served by both applicants is still well below the 964 additional patients to be

4 CL-2022-0538; CL-2022-0539

served indicated by the SHP. Thus, under the need methodology set forth in the SHP, both Projects can be approved without exceeding the established need demonstrated under the SHP.

"33. Like the home health methodology, there are a number of other healthcare services that show a finite need under the SHP. For example, the nursing home methodology sets forth the additional number of nursing home beds necessary to satisfy the projected need. Ala. Admin. Code § 410-2-4-.03. The same is true of the methodology for hospital beds and [Specialty Care Assisted Living Facility] beds. Ala. Admin. Code § 410-2-4-.02 and 410-2-4-.04. Even though this finite need results in a batching cycle, there have been a number of batching cycles over the years where SHPDA has approved multiple CON applications and awarded beds under these finite need methodologies to multiple facilities. As long as the total number of beds awarded to the multiple applicant facilities does not exceed the bed need indicated in the SHP, SHPDA precedent has shown that awarding multiple CONs is consistent with the SHP, compliant with the Agency's interpretation of the CON Rules, and is not legally prohibited. The case at hand is no different. The need methodology for home health sets forth a finite number of additional patients to be served, and, as long as the total patient projections set forth in the multiple applications do not exceed the patient need, just like when the total number of beds set forth in the multiple applications do not exceed the bed need, more than one home health agency can similarly be approved.

"34. Further, there is nothing in the CON Rules or the SHP that limits the grant of only one CON application for home health services. In fact, the SHP directly acknowledges that approving more than one applicant is permissible when setting forth the purpose behind the need methodology. 'The purpose of this home health need methodology is to identify, by county, the number of home health agencies needed to assure the continued availability, accessibility, and

5 CL-2022-0538; CL-2022-0539

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Encompass Health Home Health of Alabama, LLC Kindred at Home, LLC Amedisys Home Health and LHC Group, Inc. v. State Health Planning and Development Agency, Madison Home Health Services, LLC, and ProHealth Home Health, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/encompass-health-home-health-of-alabama-llc-kindred-at-home-llc-amedisys-alacivapp-2023.