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DIVISION OF HEALTH PLANNING AND RESOURCE DEVELOPMENT AUGUST 2001 CON REVIEW: SENTRY NORTH, L.P. D/B/A SENTRY ATTALA CONSTRUCTION OF A 60-BED FACILITY IN ATTALA COUNTY Capital Expenditure: $1,234,436 Location: Kosciusko, Mississippi I. Project Summary A. Applicant Information Staff Analysis Sentry North, L.P. is a newly formed limited partnership associated with SentryCare, Inc. which owns and operates several long term care facilities in the state. The purpose of the limited partnership is to develop and own nursing homes and assisted living facilities in the state. B. Project Description Sentry North, L.P. requests Certificate of Need authority for the construction of a 60-bed nursing facility in Kosciusko, Mississippi. The proposed 60-bed nursing facility will contain 15,653 square feet of space and will require 62.49 full-time equivalent personnel at an estimated annual cost the first year of $1,480,572. The applicant plans to finance the proposed project with a loan from Trustmark National Bank (Jackson) in the amount of $914,636 for 20 years. The reminder of $319,600 will be supplied with Partner s equity. Also, Sentry Attala will be a small but comprehensive retirement campus, offering independent/congregate living, assisted living and skilled nursing care. The applicant has requested a site inspection from the Division of Health Facilities Licensure and Certification.

Page 2 II. Type of Review Required (60-Bed Nursing Facility) This application for the construction/establishment of 60-bed nursing facility beds is reviewed in accordance with Section 41-7-191, subparagraphs (1)(a) and (2)(q)(i), (q)(ii), (q)(iii), (q)(iv), and (q)(v) Mississippi Code of 1972 Annotated, as amended (Senate Bill 2679, 1999 Regular Session), and duly adopted rules, procedures, plans, criteria, and standards of the Mississippi State Department of Health. Senate Bill 2679 authorized the Department to issue Certificates of Need during the next four fiscal years for the construction expansion of nursing facility beds in each county in the state having a need for 50 or more additional nursing facility beds, as shown in the Fiscal Year 1999 State Health Plan. Attala County is one of six counties eligible to receive a Certificate of Need for 60 nursing facility beds in Fiscal Year 2002. The department received four applications for the 60-bed nursing facility authorized for Attala County. The applications listed below were deemed complete on July 1, 2001 and entered into Review Cycle 3 as competing applications: NH-CB-0601-027 Attala County Board of Supervisors Construction of a 60-Bed Nursing Facility in Attala County Capital Expenditure: $1,825,017 NH-CB-0601-028 Garry V. Hughes d/b/a The Kennington, Kosciusko Construction of a 60-Bed Nursing Facility in Attala County Capital Expenditure: $968,424 NH-CB-0601-029 Attala Health Care Center, Inc. Construction of a 60-Bed Nursing Facility in Attala County Capital Expenditure: $1,636,760 Sentry North, L.P. d/b/a Sentry Attala Construction of a 60-Bed Nursing Facility in Attala County Capital Expenditure: $1,234,436

Page 3 In accordance with Section 41-7-797(2) of the Mississippi Code of 1972 Annotated, any affected person may request a public hearing on this project within 20 days of publication of the staff analysis. The hearing fee of $4,000 must be paid at the time of the request, to be valid. The opportunity to request a hearing expires on September 4, 2001. III. Conformance With the State Health Plan and Other Adopted Criteria and Standards A. State Health Plan (SHP) The FY 1999 State Health Plan addresses policy statements and specific s criteria and standards which an applicant is required to meet prior to receiving Certificate of Need authority to construct/establish nursing facility beds. This application is in substantial compliance with policy statements and criteria and standards for these types of projects. SHP Criterion 1 - Need Attala County is located in Long-Term Care Planning District I (LTCPDI). The FY 1999 State Health Plan shows an unmet need in Attala County of 58 nursing facility beds and a total unmet need of 283 nursing facility beds for LTCPDI. Approval of this request for 60 nursing facility beds will reduce the unmet need for nursing facility beds in LTCPD I by 60 beds. SHP Criterion 2 - Facility Size Senate Bill 2679 (1999 Regular Session) authorized the approval of a Certificate of Need for 60 additional nursing facility beds in Attala County in FY 2002, and this application is in compliance with this criterion and the statute. SHP Criterion 3 -Statistical Need/Competing Applications Attala County is located in Long Term Planning District I. The FY 1999 State Health Plan shows an unmet need in Attala County of 58 nursing facility beds and a total unmet need in LTCPDI of 283 beds. As previously mentioned, the Department received four competing applications for the 60 nursing facility beds authorized by Senate Bill 2679 for Attala County in FY 2002. Also, all

Page 4 nursing facility applications filed with the Department by June 1, 2001 for the FY 2002 authorization are mandated to be reviewed under the FY 1999 State Health Plan. B. General Review Criteria Chapter 8 of the Certificate of Need Review Manual, Revised 2000, addresses general review criteria by which all Certificate of Need applications are reviewed. This application is in substantial compliance with applicable general review criteria. GR Criterion 3 - Availability of Alternatives According to the applicant, other alternatives do exist for care of the elderly, such as community based services, personal care homes and home health; however, nursing facilities are needed to care for a percentage of the elderly who are unhealthy. GR Criterion 4 - Economic Viability According to the applicant s operating statement, gross revenues for the first three years will be $2,055,899, $2,875,740 and $2,884,020, respectively. Net income for the first three years is projected to be $22,108, $238,084 and $198,753, respectively. Consequently, the proposed project appears to be economically viable. GR Criterion 5 - Need Attala County is located in Long-Term Care Plan District I (LTCPD I). The FY 1999 State Health Plan shows an unmet need in Attala County of 58 nursing facility beds and a total unmet need in LTCPD I of 283 beds. Approval of this request for 60 nursing facility beds would reduce the unmet need in LTCPD I by 60 beds. The application contained 553 letters of support for this project and one letter of opposition from the Attala County Board of Supervisors. GR Criterion 6 - Accessibility According to the applicant, all residents of the service area, including Medicaid and Medicare recipients, medically indigent, minorities, women, handicapped persons and the elderly, will have access to the facility. The proposed site is near the hospital and medical clinics.

Page 5 The applicant projects that the payor mix will be as follows: Medicaid - 45.61 percent; Medicare - 35.09 percent; and Private Pay - 19.30 percent. GR Criterion 7 - Information Requirement Sentry North, L.P. d/b/a Sentry Attala affirms that it will record and maintain the information required by this criterion and will make it available to the Mississippi State Department of Health within 15 business days of such request. GR Criterion 8 - Relationship to Existing Health Care System There are two nursing facilities located in Attala County, totaling 270 nursing facility beds: Attala County Nursing Center - 120; and Mississippi State Veteran s Home - 150. The annual occupancy rate for the two facilities in 2000 was 97.10 percent. The applicant included a sample transfer agreement which will be used with area hospitals. The application contained 553 letters of support and one letter of opposition from the Attala County Board of Supervisors. GR Criterion 9 - Availability of Resources The applicant indicated that the methods of recruiting all required personnel will not be limited to the local area if the local market is tight, butcould be from different parts of the state or neighboring states. The applicant projects that the staffed facility will utilize 62.49 full-time equivalent personnel, costing $1,126,043 the first year. GR Criterion 15 - Competing Applications The Department received four applications for the 60 nursing facility beds authorized for Attala County in FY 2002. See Appendix I for a comparative analysis of the four competing applications. CR Criterion 16 - Quality of Care Sentry North, L.P. d/b/a Sentry Attala will be licensed under the Minimum Standards of Operations for Institutions for the Aged or Infirm by the Mississippi State Department of Health.

Page 6 IV. Financial Feasibility A. Capital Expenditure Summary New Construction Cost $889,220 Non-Fixed Equipment 170,496 Land Cost 110,799 Capitalized Interest 24,000 Other Costs 39,921 TOTAL PROPOSED CAPITAL EXPENDITURE $1,234,436 The above estimated capital expenditure is proposed for the new construction of 15,653 square feet of space at a per square foot cost of $58.25. The cost per bed, based on the total capital expenditure, is $20,574. Means Construction Cost Data 2001 shows the low range per square foot to be $69.25 and the low range per bed cost to be $30,000. This project is below the low range for both square foot and bed cost listed in Means. B. Method of Financing The applicant proposes to finance the proposed project with a loan from Trustmatk National Bank (Jackson) in the amount of $914,636 for a period of 20 years. The remainder of $319,600 will be supplied with Partner s equity.

Page 7 C. Effect on Operating Cost The applicant projects the following expenses, utilization, and results from operations the first three years following completion of the project: EXPENSES Year 1 Year 2 Year 3 Salaries and Benefits $1,126,043 1,445,497 $1,480,572 Supplies 38,937 55,788 58,488 Other Direct Expenses 418,553 588,090 592,440 Adm. and General 268,022 340,865 344,052 Other Indirect Expenses 57,069 74,824 78,420 Amortization 3,792 3,792 3,792 Depreciation 41,508 41,508 41,508 Interest 66,792 66,139 64,635 TOTAL EXPENSES $2,020,716 $2,616,503 $2,663,907 REVENUES Year 1 Year 2 Year 3 Gross Patient Revenue $2,055,899 $2,875,740 $2,884,020 Total Deductions (13,075) (21,153) (21,360) Net Revenue $2,042,824 $2,854,587 $2,862,660 Year 1 Year 2 Year 3 Occupancy Rate (%) 66.67% 95.00% 95.00% Patient Days 14,787 20,716 20,808 Cost/Patient Day $136.65 $126.30 $128.02 Charge/Patient Day $138.15 $137.80 $137.57 NET INCOME(LOSS) $22,108 $238,064 $198,753

Page 8 The applicant projects that the per diem cost to Medicaid for the first year would be $87.42. Applicant s projections appear reasonable and comparable to other nursing facilities of similar size and payor mix. D. Cost to Medicaid/Medicare The impact of the project on third party payers is as follows for the first year: Payor Mix Utilization Percentage First Year Cost Medicaid 45.61 $507,998 Medicare 35.09 $1,149,325 Private Pay 19.30 $363,393 Total 100.00 $2,020,716 V. Recommendation of Other Affected Agencies The Division of Medicaid was provided a copy of this application for comment. According to the Division of Medicaid, this project is expected to increase Medicaid expenditures by approximately $ in total funds based on a stable occupancy rate. VI. Conclusion and Recommendation This project is in substantial compliance with the criteria and standards for nursing facility beds as contained in the FY 1999 State Health Plan, the Certificate of Need Review Manual, revised 2000, and all adopted rules, procedures, and plans of the Mississippi State Department of Health. The project also complies with Senate Bill 2679 of the 1999 Legislative Session, which authorized the Department of Health to issue a CON for the construction or expansion of nursing facility beds or the conversion of other beds to nursing facility beds in each county a need for 50 or more additional nursing facility beds, as shown in the FY 1999

Page 9 State Health Plan. Attala County is one of six counties eligible to receive a Certificate of Need for 60 nursing facility beds in FY 2002. The Department received four applications for the 60 nursing facility beds authorized for Attala County. All four applications were deemed complete on July 1, 2001 and entered into Review Cycle 3 as competing applications. With competing applications, the Department must determine which applicant, if any, is the most appropriate applicant for providing the proposed service. After a thorough examination and analysis of each of the four competing applications filed for a 60-bed nursing facility in Attala County, including the development and utilization for a comparative analysis and consideration of the comments from the Division of Medicaid, the Division of Health Planning and Resource Development has determined that the application submitted by Garry V. Hughes d/b/a The Kennington is the most appropriate applicant to provide the proposed nursing facility services in the 60-bed facility authorized by Senate Bill 2679 for Attala County in FY 2002 (See Appendix I). Approval of this application precludes approval of any other competing application in Attala County. Consequently, the Division of Health Planning and Resource Development recommends disapproval of the application submitted by Sentry North, L.P., d/b/a Sentry Attala.

APPENDIX I COMPARATIVE ANALYSIS PROPOSED 60-BED NURSING FACILITIES ATTALA COUNTY (THIRD YEAR OF OPERATION) Attala HCC Kennington Sentry Attala Attala CC Size (Sq. Foot) 1 26,136 3 15,919 4 15,653 2 22,484 Capital Expenditure 3 1,636,760 1 968,424 2 1,234,436 4 1,825,017 Cost/Sq. Foot 2 $53.90 1 $50.72 3 $58.25 4 $73.71 Cost/Bed (Total Cost) 3 $27,279 1 $16,140 2 $20,574 4 $30,417 Gross Revenue $3,199,205 $2,897,825 $2,884,020 $2,670,768 Deductions -0- ($1,150,106) ($21,360) (396,100) Net Revenue $3,199,205 $1,747,720 $2,862,660 $2,274,668 Expenses $3,095,508 $1,604,823 $2,663,907 $1,861,691 Net Income $103,696 $127,540 $198,753 $412,978 Occupancy Rate Patient Days 95.0% 20,805 99.0% 21,681 95.0% 20,808 98.0% 21,462 Cost/Patient Day Charge/Patient Day $148.79 $153.77 $74.02 $80.61 $128.02 $137.57 $86.74 $105.99 Personnel Required First Year Cost 1 79 $914,804 2 77 $611,069 3 62.49 $1,126,043 4 55 $744,918 Medicaid Utilization (%) 32.5 42.0 45.61 60.0 Medicare Utilization(%) 1 42.5 3 35.0 2 35.09 4 20.0 Private Pay Utilization (%) 25.0 23.0 19.30 20.0 Cost to Medicaid (1 st yr) 1 $301,688 2 $441,782 3 $507,998 4 $684,008 Per Diem Costs Medicaid (1 st yr) 1 $70.64 2 $71.59 4 $87.42 3 $73.19 Continuum of Care (yes/no) 1 yes 1 yes 1 yes 4 no Community of Support Letters 4 174 1 1,635 3 553 2 1,389 Signed Agreement -1 yes -1 yes -1 yes -1 yes Composite Score 17 16 26 34