20081126 MSBCBS ASC and Ambulatory Care CON standards comment

900 Pennsylvania Avenue P O Box 1353 Charleston, WV 25325 Ph 304.347.7779 Email and Hand delivery November 26, 2008 West Virginia Health Care Authority Dayle Stepp, Director, Certificate of Need 100 Dee Drive Charleston WV 25311 Re: Comments on Certificate of Need Standards for Ambulatory Care Centers Version 10/5/92 Dear Mr. Stepp: As an insurer and third party administrator of health benefits for West Virginia residents and employers, Mountain State BlueCross BlueShield (MSBCBS) appreciates the opportunity to furnish comments related to the Certificate of Need (CON) standards applied to the development and oversight of ambulatory care, to include Ambulatory Surgical Centers (ASCs) and diagnostic centers. Please understand that we support the Certificate of Need (CON) process and the critical function identifying unmet need imbedded in the CON logic. We also support each CON guideline intended to avoid the development of services exceeding the population of patients available to fiscally support them. We strongly believe over supply of services leads to excess cost in the healthcare economy. Unfunded health care development leads to higher cost for care and over utilization. This translates to increased employer or health plan funding requirements, often resulting in additional transfer of premium or cost sharing obligations to employees/retirees/plan participants. While some may tout ...