Imperial Valley Coalition for Sustainable Healthcare Facilities

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The Machine Grinds On

On Thursday June 13, 2024, the Imperial Valley Healthcare District (IVHD) passed a resolution to recommend the dissolution of the Pioneers Memorial Healthcare District (PMHD) on December 1 and Heffernan Memorial Healthcare District on October 1, 2024.  This action was taken in following the mandates established in AB918.  What does “dissolution” mean?  

Section 32499.95(b) states:

“Effective on the respective date of their dissolution, all assets, rights, and responsibilities of the Heffernan Memorial Healthcare District and the Pioneers Memorial Healthcare District are transferred to the Imperial Valley Healthcare District. As of the effective date of the dissolution, the Imperial Valley Healthcare District shall have ownership, possession, and control of all books, records, papers, offices, equipment, supplies, moneys, funds, appropriations, licenses, permits, entitlements, agreements, contracts, claims, judgments, land, and other assets and property, real or personal, owned or leased by, connected with the administration of, or held for the benefit or use of the Heffernan Memorial Healthcare District or Pioneers Memorial Healthcare District. Accounts payable and all other contract obligations shall be transferred to the Imperial Valley Healthcare District.”

PMHD will cease to exist as a district.  The hospital will continue operations under the newly formed IVHD and governed by a Board of seven individuals, one of which represents PMHD. 

As I have stated multiple times in these articles, AB918 while good in concept has many flaws in the implementation of a single healthcare district.  Here are a few for you to consider: 

  1. AB918 requires that a feasibility study by Kaufman Hall and LAFCO be completed.  While these studies were completed, they were clearly flawed, incomplete, used outdated information, and made no recommendations on feasibility.  IVHD has determined that the acquisition of ECRMC and the formation of a single healthcare district is feasible with no explanation of how this determination was made. 
  2. While creating a single healthcare district, dissolving existing districts should be the last and final step.  A significant amount of work is required before this can occur, i.e. acquisition of ECRMC which requires extensive due diligence, property appraisals, identifying a funding source for IVHD, LAFCO approval of a funding source and creating a ballot initiative for the November election.  
  3. AB918 created impossible deadlines that mandates this be completed by January 1, 2025 which now forces IVHD to follow.  Such deadlines forces IVHD to rush their determinations for the sake of meeting deadlines, without any consideration for the negative impacts that follow rushed decision making. Additionally, transparency of Board determinations is compromised in the course of meeting these deadlines.  
  4. AB918 also did not provide any solution to the potential failure of the ballot initiative on a new funding source for IVHD which would most likely be a county wide property tax.  The outcome would then be 2 dissolved hospital districts and 1 newly formed district with 2 hospitals and no funds to operate the district other than revenue generated by patient billing.  What was accomplished in the end given such an outcome? NOTHING EXCEPT A DAMAGED HEALTHCARE SYSTEM. 
  5. A dissoution does not change the current tax structure.  PMHD will continue to pay taxes where they have no control and HMHD pays for no hospital. 
  6. AB918, Section 32499.6(4)(A) states, “All existing hospital licenses and certifications of the Pioneers Memorial Hospital and Healthcare District shall be transferred to the Imperial Valley Healthcare District when applicable in order to avoid a disruption in providing health care services. The initial board of directors shall initiate the process of applying for any licenses and certifications that cannot be transferred to the Imperial Valley Healthcare District within a year of formation.”  

This assumes that all the government agencies such as Centers for Medicare and Medicaid (CMS) and Department of Healthcare Services(DHCS), contract providers, vendors, and other established agreements will be reviewed, updated or renegotiated without interrupting delievery of services.  AB918 can say it will try to avoid disruption of services, however that does not mean it will happen.  Remember this is the State and Federal Government we are talking about. 

As this process grinds on many questions continue to surface.  

AB918 mandates 3-4 public meetings to keep the public informed about the components of the process.  Will IVHD meet this mandate?  

Section 32499.6 (A-D)

(6) The board of directors shall hold a minimum of three public meetings between the effective date of this chapter and January 1, 2025, as follows:

(A) During the first public meeting, the board of directors shall inform the public of the establishment of the Imperial Valley Healthcare District, the cost savings of having one countywide health care district, and the findings of the financial feasibility studies conducted by the Imperial County LAFCO and Kaufman Hall. The first public meeting shall be held by March 1, 2024.

(B) During the second public meeting, the board of directors shall inform the public of the recommended permanent funding source mechanism for the Imperial Valley Healthcare District. 

(C) During the third public meeting, the board of directors shall inform the public about the acquisition of the El Centro Regional Medical Center.

(D) If the board of directors votes to acquire the El Centro Regional Medical Center, the board of directors shall hold a fourth meeting. During this meeting, the board of directors shall disclose the terms of the acquisition to the public and present a financial plan to finance the acquisition and ongoing operations of hospitals in the district.

While the first meeting was completed, it is questionable as to the findings of financial feasibility. The second meeting will disclose the recommendations on a permanent funding source. IVHD must schedule this meeting prior to August 8th which is the deadline to place initiatives on the November ballot.  The clock is ticking!!!

While negotiations for the acquisition of ECRMC continue, just how much information will be shared with the public during meeting #4 given that feasibility determinations were not shared with the public? 

What is IVHD’s plan to manage 2 hospitals (if ECRMC is acquired) if a ballot initiative fails leaving IVHD without a permanent funding source?  

How will IVHD ensure the continuity of care while existing licenses, contracts, leases and agreements will need to be renegotiated? 

Just think, all this without your vote! 

How is your democracy feeling today?  

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