Ceasing hospital operations is a complex process that involves a range of critical planning and coordination steps to ensure the health, welfare and safety of hospital patients and mitigate legal and other risks for the hospital and its officers and directors. As hospitals and their governing bodies make tough decisions and prepare to cease operations, it is important to put in place comprehensive closure plans, and communicate details of these plans to stakeholders and regulatory bodies.
Although not intended to be an exhaustive checklist, the following top ten issues should be considered as part of any closure process. To develop a final plan, each hospital should carefully review and consult with counsel on the impact of these considerations on the organization’s unique circumstances. Depending on the closure plan, this may require multiple sequential notices to regulators or others if, for example, the number of available beds are stepped down over a number of weeks or months, or where certain services are discontinued prior to the final shutdown.