Because two hospitals cannot be justified, the order of Board consideration could be critical. Generally, the Board considers CON applications in the order they are received, although the Board may not follow this rule when competing applications aim to satisfy the same projected need. The main problem in this situation is that once one project is approved, the other is essentially unnecessary. Expect the Board to address this concern before it considers these two applications.
The average amount of time to construct a new hospital is five years. Both hospitals could argue that failing to start construction now may create patient access issues in the near future, especially if a hospital is not operational when patient need surpasses the 100 bed benchmark. The hospitals have a good point here—McHenry County’s M/S bed need could exceed 100 in just one or two years.
The Hospitals may need to explain how new population information released by the U.S. Census Bureau in March 2011 affects their CON applications. The key question is whether McHenry County’s population growth will continue at a rapid pace.