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Connecticut rehab providers urge OHS to deny Encompass Brantford 50‑bed IRF, citing workforce and financial harms
Summary
Witnesses from Gaylord Hospital and Hospital for Special Care told the Office of Health Strategy that Encompass Health's Brantford application overstates need and would harm clinical training, research, staffing and the finances of safety-net providers; they urged denial and pointed to overlapping capacity and payer shifts.
At a hearing before the Connecticut Office of Health Strategy, witnesses for Gaylord Hospital and Hospital for Special Care urged OHS to deny Encompass Health's application to open a 50‑bed inpatient rehabilitation facility in Brantford, arguing the proposal overstates need and would worsen staffing and financial pressures for existing providers.
The witnesses laid out three central concerns. A Gaylord Hospital physical therapist said the proposal would hurt patient care and training and aggravate workforce shortages. "When Hartford Hospital opened their IRF, we actually decreased by 35%," the witness said, and added Gaylord last year treated 45 patients from Brantford and about 100 from surrounding towns. The witness highlighted Gaylord's specialty accreditations, a roughly 50% discharge‑to‑home rate across payers, and an average occupancy of about 82% over seven years as evidence of a high‑quality, long‑standing regional service.
George Cariocco, chief strategy officer for Gaylord Hospital, challenged the applicant's need analysis. He said Encompass's methodology does not properly incorporate Medicare program data or Connecticut‑specific utilization and fails to account for major differences between traditional Medicare and Medicare Advantage. "Not factoring in the significantly lower IRF utilization by Medicare Advantage beneficiaries ... results in an artificially inflated bed need calculation," Cariocco testified, and asked OHS to deny the application.
Laurie Bridal, senior vice president of Hospital for Special Care, said HSC's role as a safety‑net provider would leave it particularly vulnerable if higher‑paid Medicare and commercial referrals shift to a new for‑profit IRF. Bridal testified HSC serves a largely Medicaid population (more than 80% of patient days), currently has 53 vacant clinical positions (including 33 registered nurses and 14 CNAs), and has recently added $2.5 million in contracted labor costs. She described HSC's current financial strain and said "these losses are not sustainable for an independent not‑for‑profit health care" provider. HSC asked OHS to deny the application, arguing the record does not show an unmet state need and that additional freestanding capacity would be premature given recent approvals for Danbury and Waterbury.
Applicant counsel questioned witnesses about data sources, whether proprietary Medicare Advantage data had been purchased and whether it could be shared with OHS. Cariocco confirmed Gaylord had purchased proprietary runs from "Watson Policy Analysis," but said he would defer to counsel about releasing that data to OHS. The record includes differing bed‑need estimates presented in testimony and exhibits, and interveners urged OHS to rely on Connecticut‑specific utilization to avoid inflating need.
The hearing recessed for a 20‑minute break; OHS said it would reconvene at 4:25 p.m.
