TO WHOM IT MAY CONCERN

Ladies and Gentlemen:

I am a somewhat recent resident of St. Helens and wish to comment on the proposal to construct and operate a new hospital here. The proposal underlies Ballot Measure 5-123. I have reviewed the Feasibility Study, dated January 17, 2003 and believe that 1) the Study has not been critically enough analyzed or reviewed, 2) was substantially flawed in its findings and 3) was adopted by the Hospital Coalition without sufficient knowledge of hospital administration. I also believe that filing Ballot Measure 5-123 was extremely premature and is in large part unsupported by the Study.

In 1990 the former District Hospital in St. Helens closed due to lack of sufficient financial resources to sustain necessary services and financial stability to retain hospital licensure status. Prior to that event   I worked for the State of Oregon and was the person in charge of the Certificate of Need (C/N) program and the Rate and Budget Review program applicable to all of Oregon's 82 hospitals and over 200 nursing homes, whether public or private.

These two healthcare facility regulatory programs required me to identify healthcare service needs and adjudicate applications from all healthcare facilities in Oregon so that they may, or may not, provide new healthcare services, provide new beds or close existing beds or services.

I held those positions for approximately 17 years from 1971, the year I was recruited by the State of Oregon Health Planning and Development Agency (subsequently evolving into various other agencies within State government) to develop and install the C/N program, until 1998. In that year I left the State agency to become Vice President of Health Economics at the then, Oregon Association of Hospitals (now Oregon Association of Hospitals and Healthcare Systems) the "trade" organization for hospitals.

Prior to returning to Oregon in 1971 to develop and administer those programs and accept those responsibilities, and beginning in 1965, I was in healthcare administration in San Francisco, first as Assistant Administrator of Planning for a large Jewish hospital in that city and later, as a Healthcare Administration consultant with the international CPA firm KPMG Peat Marwick, having healthcare provider clients all across the United States. My clients included several states, where I established C/N programs similar to that of Oregon's, often doing so under contract to the Federal Government.

Concurrent with my responsibilities at the State level, I was also named by the Governor as Director of the Hill-Burton program, a program established and funded completely by the Federal government to construct acute care and long-term care facilities. The Hill-Burton program also required those facilities that had received Hill-Burton construction funds to provide a required annual unreimbursed volume     (a minimum of 10% annually of gross revenues) of healthcare services to those unable to pay for services.

I retired from professional life in 1990 and maintained a small consulting practice, working with healthcare facilities on operational matters. I closed my consulting practice in September 2001.

MY REVIEW AND COMMENTS ON THE PROPOSAL TO BUILD A NEW HOSPITAL

The Hospital Coalition proposes to establish a 15-bed St. Helens Hospital (SHH) with the market area from which its patients would come said to be "the south county community". The market area is described as including all the communities on the Hwy. 30 corridor from Deer Island to Scappoose.