The Mass. Department of Public Health has issued its findings regarding the proposed plan by UMass Memorial Medical Center (UMMMC) to close 13 of 28 inpatient psychiatric beds at its University Campus at a time when the psychiatric unit is nearly always full and patients are boarding in the hospital’s emergency department for several hours to several days waiting for needed care and services. The DPH letter finds that these beds provide an essential service that is “necessary for preserving access and health status in the hospitals’ service area.” The full text of the letter is included at the end of this press release or you can obtain a PDF of the letter by emailing firstname.lastname@example.org.
The DPH based its finding on its review of the issue and the testimony at a packed public hearing held on March 30 where dozens of mental health advocates, caregivers, community members, former patients and elected officials opposed the closing and expressed concern that elimination of these services will negatively impact the care provided to patients, while also leading to an increase in the boarding of psychiatric patients both at UMass Memorial Medical Center, and other hospitals in the region.
The DPH letter highlights a number of serious issues and concerns identified by opponents to the closure and calls upon UMMMC administration to provide detailed responses to these concerns. This includes information to substantiate the management’s claims that alternative providers of mental health services in the region can accept and properly treat the patients currently cared for at the existing psychiatric unit, information on transportation issues and increased travel time to access care at alternative facilities following the closure of these beds, and information on how the closure will impact occupancy rates at surrounding hospitals and facilities. The letter also calls into question UMass administration’s failure to engage with the community in the development of this plan, citing “concern was expressed that the hospital has failed to appropriately identify and subsequently communicate effectively with community groups and health care coalitions regarding its plans to discontinue operation of 13 inpatient psychiatric beds and for ensuring access to care.”
“We greatly appreciate DPH’s findings that this is an essential service, and that the loss of this service will deprive residents throughout this the region the care they deserve,” said Lisa Goss, RN, psychiatric nurse who has worked on 8 East (the unit to be impacted by the closure) for more than 12 years. “Our hope now is that this finding, and strong outcry against this plan from our community convinces UMass to keep these beds open so we can continue to provide excellent care for our patients suffering with acute mental health conditions.”
In January, the management of UMass Memorial Medical Center announced plans to close 13 of the 28 psychiatric beds on 8 East, its busy inpatient psychiatric unit, and to convert these beds to medical surgical beds.
On 8 East staff care for patients from the age of 16 up to geriatrics. They suffer from a range of mental health issues such as depression, bipolar disorder, anxiety, schizophrenia, addiction, and also may be suicidal, self-injurious, and have homicidal thoughts and behavior. These patients often also need treatment for other medical issues which they are able to receive on 8 East because it is a medical psychiatric unit within an acute care hospital.
This unit is nearly always full, while at the same time, the UMass University and UMass Memorial emergency departments are overburdened with psychiatric patients waiting for a bed on this or any other unit in the state that can take them These patients often wait several hours to several days for a bed.
Full text of the DPH Letter
On March 30, 2017, the Department of Public Health (“Department”) held a public hearing in response to the notification received from you on behalf of UMass Memorial Medical Center (“Hospital”) regarding the proposed plans to discontinue operation of a 13 inpatient psychiatric beds, effective June 1, 2017. As a result of its review, including testimony presented at the hearing, the Department has made a finding that the services provided by the Hospital are in fact necessary for preserving access and health status within the Hospital’s service area.
Accordingly, pursuant to 105 CMR 130.122(G), the Hospital is required to prepare a plan that details how access to inpatient psychiatric beds will be maintained for the residents of the service area. The plan must be submitted to the Department not later than within 15 calendar days of receipt of this letter. The Hospital’s plan must include the elements specified in 105 CMR 130.122(G) as listed below:
(1) Information on utilization of the services prior to proposed closure;
(2) Information on the location and service capacity of alternative delivery sites. Include an explanation of the basis for the Hospital’s determination that the alternative delivery sites do or do not have the capacity (necessary space, resources, etc.) to handle the increased patient volume at the identified sites. To support that assertion, please provide the following specific details:
(a) Current utilization at these alternative sites;
(b) Type of services available at the alternative sites;
(c) Type of medical diagnoses accepted; and
(d) Adequacy of space and resources at the alternative sites.
(3) Travel times to alternative service delivery sites, for both peak and non-peak travel times, and an explanation as to the source for this information or what these estimates are based on;
(4) An assessment of transportation needs post discontinuance and a plan for meeting those needs;
(5) A protocol that details mechanisms to maintain continuity of care for current patients of the discontinued service; and
(6) A protocol that describes how patients in the Hospital’s service area will access the services at alternative delivery sites. The protocol should specifically address the following:
(a) The process that will be employed to effectively refer patients to other facilities or providers;
(b) The impact that this may have on the current occupancy rates at alternative delivery sites;
(c) The ability of the alternative delivery sites to meet the needs of these patients; and
(d) Other alternatives if medical needs cannot be accommodated at the proposed alternative sites.
In addition to the regulatory elements listed above, and in light of the Department’s review of testimony on the proposed closure, your plan must also address the following:
(1) Cultural and Linguistic Needs: Information regarding the Hospital’s plans to meet the cultural and linguistic needs of patients from the greater Worcester area community when referring these patients to alternate delivery sites outside the Worcester community.
(2) Transportation: Based on testimony submitted to the Department and presented at the March 30, 2017, hearing, concern was expressed that the lack of public transportation from Worcester to facilities other than the UMass Memorial Medical Center’s inpatient unit will limit the ability of family and friends to visit and provide support. The plan which you are required to submit must address alternate methods of transportation for family and friends who wish to visit and will now have to travel outside the Worcester community once the beds have closed.
(3) Re-open Out of Service Medical/Surgical Beds: Based on testimony submitted to the Department and presented at the March 30, 2017, hearing, concern was expressed that the Hospital has not adequately assessed the timing and impact of bringing two out of service Medical/Surgical units, West 1 and West 2, back into service. The plan which you are required to submit must address the Hospital’s assessment for the re-opening of West 1 and West 2 and how that would impact the need to close and convert the 13 inpatient psychiatric beds at the University Campus to medical/surgical beds.
(4) Insurance Plans Accepted: Based on testimony presented at the hearing on March 30, 2017, it is unclear as to whether all insurance plans accepted at the Hospital will be accepted at the alternative service sites proposed. The plan which you are required to submit must address which insurance plans are now accepted at the Hospital, and in the event that insurance plans now accepted at the Hospital are not accepted at the alternative service sites, what will be done to mitigate the impact on patients.
(5) Engagement with Community Groups and Health Care Coalitions: Based on testimony submitted to the Department and presented at the March 20, 2017, hearing, concern was expressed that the Hospital has failed to appropriately identify and subsequently communicate effectively with community groups and health care coalitions regarding its plans to discontinue operation of 13 inpatient psychiatric beds and for ensuring access to care. The plan which you are required to submit must address the identification of and ongoing engagement with community groups and health care coalitions that are reasonably expected to have an interest in the beds closure and outreach through local elected officials, community leaders and with the community at large.
Under the provisions of 105 CMR 130.122(H), the plan the Hospital submits to the Department will be reviewed to determine if it appropriately assures access to the essential services in question following the plans to discontinue operation of 13 inpatient psychiatric beds.