Save Laguna Honda Hospital, SF 120 Beds Close to Goal —Threat of 769-Bed Closure Looms

Save Laguna Honda Hospital, SF 120 Beds Close to Goal —Threat of 769-Bed Closure Looms

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Why this petition matters

Help Save 120 Beds at Laguna Honda Hospital in San Francisco

Petition to:
Dan Bernal, President, San Francisco Health Commission, and
Supervisor Aaron Peskin, President, San Francisco Board of Supervisors

San Francisco is facing the loss of 120 skilled nursing facility (SNF) beds at Laguna Honda Hospital by having to convert three-person suites to two-person rooms.  At the time the replacement hospital was designed and opened in 2010, three-person occupancy was allowed in SNF’s by the federal Centers for Medicare and Medicaid (CMS), and had been approved before the rebuild began.

On March 21, 2023, LHH’s acting CEO, Roland Pickens, testified (in part) to the San Francisco Health Commission that:

[When] the 2016 Federal requirement that was put into place …  required ‘newly-certified’ facilities to have no more than two residents per room in a skilled nursing facility we shared our grave concerns … that Laguna Honda might be subject to complying with that, because to date that’s the best information we’ve been provided that we must comply [and eliminate 120 beds at LHH].  We continue to work with our Federal partners primarily through the City Attorney’s Office to pursue all avenues to make that the reality to be able to restore those 120 beds.  We continue that dialog on a continual basis.”

A public records request for a letter from CMS/CDPH directing LHH to eliminate 120 beds turned up no responsive records, meaning LHH has not been provided with a written order to do so.  Pickens previously claimed legislation was pending in the U.S. Congress to permit “grandfathering” of three-person rooms.  He was referring to proposed CMS rulemaking in 2019, which has since been approved.

Saving LHH’s Bed’s Only Requires a Waiver Request

42 CFR §483.90(e)(3)(ii), as of March 3, 2023 provides that survey agencies — in this case the California Department of Public Health (CDPH) — may permit and grant a variation on its number-of-patients-per-room rule when facilities request in writing an exemption that the variation to 42 CFR §483.90(e)(1)(i) "will not adversely affect residents’ health and safety.”  Some SNF’s in California have obtained waivers allowing for four- to six-patients per “room.”

Given San Francisco’s severe shortage of SNF beds, the Health Commission and Department of Public Health claimed it would do “everything it can” to save LHH’s 120 beds.  But it hasn’t submitted a written waiver request to CDPH yet!  As LHH’s governing body, President Bernal and the Health Commission — and the Board of Supervisors — should take action and direct LHH and Mr. Pickens to submit a written request to CMS/CDPH seeking an exemption to CMS’ two-patients-per-room rule.

This petition asks Health Commission President Bernal and Board of Supervisors President Peskin to do “everything thing they can” to ensure a written waiver request to save the 120 beds at Laguna Honda Hospital is submitted to CMS/CDPH.

Severe Shortage of SNF Beds in San Francisco

Between May 1997 and August 2022, public records show San Francisco lost 1,381 SNF beds in county.  Losing 120 more beds at LHH will push that to 1,501 lost SNF beds, leaving only 2,161 remaining. 

"Prop Q” hearings are required when private-sector hospitals propose reducing or eliminating services they provide to the community.  Between 2002 and 2015, San Francisco lost 926 hospital-based SNF beds.

Those closures have been detrimental, resulting in massive out-of-county discharges for patients needing SNF level of care.

Unfortunately, closure of public-sector facilities — like LHH — aren’t covered by the “Prop Q” Ordinance, and their SNF beds can be closed without holding a public hearing before the Health Commission or the Board of Supervisors.

If LHH loses 120 beds, it will only have 649 remaining, half the 1,200 beds it had before 2010.

Massive Out-of-County Discharge History

Between  2006 and 2019, SFDPH public records responses revealed 1,736 out-of-county discharges for SNF placement, based on very limited data from SFGH and LHH for 13 years, plus two private-sector hospitals — but only across two years.

In May 2022, the San Francisco Board of Supervisors passed Ordinance #77-22 requiring private-sector hospitals report out-of-county discharge data for patients discharged for both Sub-Acute SNF level of care, and SNF-level of care.  A new report issued on April 4, 2023 revealed there were 4,186 transfers and discharges of patients to out-of-county SNF’s alone across all San Francisco hospitals in calendar year 2022, and 4,185 such discharges in 2021 to out-of-county SNF’s.

Help Save LHH’s 120 Beds to Prevent Out-of-County Discharges

Sign the PetitionUrge the Health Commission and Board of Supervisors to Submit a Waiver Request to CDPH!

935 have signed. Let’s get to 1,000!