Primary care clinics on Sargent Drive delayed

NEW HAVEN — If you are located in a flood zone, you are bound to run into problems.

Yale New Haven Hospital knows this now, which is why its proposal to relocate its primary care clinics to 150 Sargent Drive, has been delayed for almost a year.

The Office of Health Strategy recently ordered the public hearing on the proposal be reopened and the hospital answer questions on its new opening date; the impact of amended Title X rules on abortion services and why it rejects running a shuttle service for patients from the current clinic sites.

The hospital’s pediatric unit will be run by the Fair Haven Community Health Center, while adults will be served by the Cornell ScottHill Health Center under a new entity they are calling the New Haven Primary Care Consortium.

On upgrading the facilities at 150 Sargent Drive, where the hospital currently offers some services, the hospital discovered that it had to flood-proof certain parts of the building. The National Flood Insurance Program coordinator didn’t weigh in with an approval until late February.

While the radiology and blood draw upgrades on the first floor had been approved for phase one, with work scheduled to be completed by March 2020, the second floor, which needs to be abated, won’t be finished until July 2020.

Because of this, the hospital has put off transitioning to the new site to late summer 2020, instead of the original September 2019 date. All of this is contingent on City Plan Commission approval on May 15.

On the controversial amendments to Title X, the hospital said the impact on its plans for the clinics were “as yet unknown,” but the rules do apply to both clinics.

Basically, the clinics “may not perform, promote, refer for, or support abortion as a method of family planning, nor take any affirmative action to assist a patient to secure such an abortion.”

To this end, it can recommend a list of providers, that includes “comprehensive primary care providers some, but not the majority, of which also provide abortion as part of their comprehensive health care services.” It does allow referral for abortion because of emergency medical situations, such as an ectopic pregnancy. There can be “nondirective pregnancy counseling,” where abortion may be included in a list of options, although it may not be the only option. The material has to be presented in “factual, objective, an unbiased manner.”

The harder rules involve the separation of the Title X project physically and financially from abortion activities. “Mere bookkeeping separation of Title X funds from other monies is not sufficient,” the hospital wrote in its letter to the Office of Health Strategy.

Physical separation includes separate accounting records; shared phone numbers, email addresses, websites; separate personnel, electronic or paper-based health care records and workstations.

“As reflected in this list of factors, the concept of ‘physical separation’ is very broad, extending beyond whether the Title X project and the prohibited activities are conducted in distinct and separate facilities. It is unclear as of yet how HHS will apply these concepts and whether there will be a process for confirming with HHS whether sufficient separation has been maintained,” the hospital wrote.

Yale New Haven Hospital offers abortion services at a separate site.

The effective date on the final rule change is May 3,with compliance on nondirectional pregnancy counseling set for July 2; the rules on physical separation is mandatory as of March 3, 2020.

On providing a shuttle service from 20 York St. and the St. Raphael campus to 150 Sargent Drive, the hospital, as it had answered in December, said it would not materially improve the situation for persons dependent on inconvenient bus schedules.

“The applicant has concluded that a door-to-door ride service is the most patient-centered and effective option to meet the need for the majority of patients” facing transportation challenges to access the new site.

The hospital also sent the Office of Health Strategy documentation on how it will bill patients unable to pay for medical evaluation and treatment.

The Office of Health Strategy has to approve the hospital’s Certificate of Need application to proceed with its plans. YNHH has to show the proposal is financially feasible, improves the quality of care, accessibility and cost effectiveness.