On October 3, GNYHA submitted comments in support of the New York State Department of Health’s (DOH’s) proposed rule making that would substitute prior limited review for administrative review with respect to non-clinical construction projects with costs between $3 million and $10 million under the State’s certificate of need (CON) program. According to the proposed rule, the new reduced level of CON review would apply to projects that do not relate to a change in clinical service or equipment and would include, but not be limited to, projects such as information systems, exterior building envelopes (e.g., windows, roof, and wall repairs), parking garages, dietary, solid waste and/or sewage disposal. GNYHA believes that the proposed change, if adopted, will help reduce costs and enhance efficiencies for providers and DOH alike without undermining the goals of the State’s CON program.  
     
The proposed rule making, which appeared in the August 20, 2008, New York State Register, reflects efforts by both GNYHA and the Healthcare Association of New York State to simplify CON approval requirements. In writing in support of the proposed rule making, however, GNYHA also strongly recommended that DOH increase the State’s CON cost thresholds more generally; eliminate the need for review of all non-clinical projects, regardless of cost; methodically review the remaining projects and equipment with an eye toward eliminating unnecessary reviews; and streamline the process for reviewing applications in general. GNYHA also noted that these additional recommendations are not intended to hold up the rule making currently under consideration. These recommendations, however, do reflect comments that GNYHA formally presented at a September 18 special meeting of the Planning Committee of the State Hospital Review and Planning Council. At that meeting, GNYHA urged the State to undertake broad-based reform of its CON program, which, under its current construction,  no longer effectively serves many of its intended purposes.  GNYHA’s recommendations on CON reform can be found at http://gnyha.org/7648/file.aspx.