FTC Requests Public Comment on ProMedica Health System's Application to Approve Divestiture of former Rival St. Luke's Hospital #00002

Submission Number:
Dennis Chelminski
Initiative Name:
FTC Requests Public Comment on ProMedica Health System's Application to Approve Divestiture of former Rival St. Luke's Hospital
The local area knew that St. Luke's was struggling financially prior to becoming part of Promedica. Recently I and my family has utilized this facility and has made improvements to the range and quality of services. Is there an operating plan post divesture that reflects that St. Luke's can be a going concern ? I believe the FTC is targeting the wrong part of the equation. The large insurers are merging which make them stronger and have more leverage on the contracts they sign with the Medical Systems. Like most U.S. Companies I was each in a dilemma whereas deciding how to provided health care plans to our employees with annual increases of 10% to 20%. I changed plan coverage and I pushed cost to the employees who already were hurt by lack of annual pay increases. We addressed all the consumer related practices with education. etc. Therefore, the big hospitals with leverage to counter the leverage large insurers have is an answer to at least part of our health care system problem. I also use the services of Cleveland Clinic and have watched that organization grow. Their size and leverage has benefited their premier services known globally. The FTC also in other industries have allowed mergers and acquisitions that to the consumer did not make sense but did not greatly effect them as Health Care cost. There is great need for the service area to have St. Luke's hospital. Increased population growth has been south and west of their location. Perrysburg, which is a 10 minute commute to St. Luke's, has grown in population from 12,119 in 1990 to 21,377 in 2013. In my opinion the need justifies Promedica supported hospital versus a stand alone entity that will have difficulties with capital improvements and medical device requirements. Promedica after divesture will probably build a medical facility in this service area and the capital to fund this expansion could be utilized for improved health care services not just brick and mortar. Personally I feel the improved Emergency care capacities has improved as I have utilized the facility a number of times since living in Perrysburg from 1978 to 2016. This has been the result of having more confidence that it was part of the Promedica system. In Toledo we do have competitive Hospitals with one of them strong as Promedica with the other now in trouble with their medical educational requirements requiring them to sign agreements with Promedica to join resources. Does this lead to a merger down the road ? Hence, a further result of weak organization that cant survive as a competitive Health Care provider. As I understand from the materials the idea that an outside hospital could come in to buy St. Luke's. Owning one facility in the community does not promote belonging to the community. The health care systems in the community give back to the community in a lot of different ways. I believe both Promedica and Mercy have done a great job of supporting the community. We cant forget about the team of Doctors and Nurses that are trained and supported by the organization and are part of the Promedica network. in summary, I feel the deconsolidation decision may have been warranted in 2010 but the Health Care system has changed in 6 years. We need strong and properly funded systems to capitalize on volume to defray the increasing cost of technology equipment and training. Dennis P Chelminski Retired CPA