We have reviewed the GAO Draft Report on Health Facilities Construction and find no problems with the contents or the recommendations. It should be noted that we have only reviewed that portion of the report which you furnished us (Pages 25-28, 41-61, and 144-146), which deals with the construction requirements. Our comments likewise address only the construction requirements and are not intended to reflect any opinion on the organization or management of the respective agencies noted in the report. Your report has clearly identified the multiplicity of conflicting and duplicate codes and regulations and recognized that the power to develop and enforce building codes is a State responsibility. It was also noted that the private groups that are in a position to develop commonly accepted performance criteria generally find that they are not equipped to perform the research necessary to develop this criteria. We concur with your conclusions that "the Federal Government could provide the leadership necessary to start such a movement, particularly in the areas of research." We appreciate the opportunity to comment on the subject report and are prepared to meet further with your staff as required. Sipceraly, Киви LAWRENCE M. KUSHNER 86-379 0-72-10 APPENDIX VII American Hospital Association 840 NORTH LAKE SHORE DRIVE CHICAGO, ILLINOIS D0011 The American Hospital Association is pleased to have been given the it. First, the reactions of our staff people meeting with your representatives were highly complimentary of the magnitude of the work which you have undertaken and of the depth of the analysis. With respect to some specific comments, it was noted that your draft report did not touch upon the question of priorities with respect to specific recommendations but left that question to the judgment of others. Perhaps some indication of priorities would be helpful to the Congress or the Administration in any implementation of your recommendations. A second specific relates to the concept of construction management. While the draft report does mention the concept, it has not been given the emphasis which our staff feel it may well deserve. Lastly, with respect to the recommendation concerning the re-use of existing hospital designs, our staff expressed a reluctance to give that concept as much emphasis as the report indicates. The potential of an economic waste of construction capital and an increase in operating cost through use of an inappropriate design may well outweigh the savings in architectural and design fees. APPENDIX VII Mr. Martin/2 10/25/72 With respect to Enclosure C of your draft report, many of the areas covered are those which this Association has encouraged and attempted to implement for several years. Outpatient care, home care, transfer of hospital patients to extended care and convalescent care facilities, utilization and peer review, shared services, planning agencies, broadening of health insurance coverages to include other than acute hospital care, are elements of better and less expensive health care which we have long espoused. In this regard, you may be interested in our Quality Assurance Program. This has just been released within the last month or so. Mr. Sale, of our Division of Hospital Medical Staffs, with whom you met with respect to the section on Utilization Review, has given you a copy. While we have no specific comments with respect to Enclosure C, the draft report points out at some length the potential of savings resulting from a shared laundry service but makes only a casual reference to the deterrent in Section 501 (e) of the Internal Revenue Code which forces hospitals into other channels to achieve this cost-saving result with respect to laundries channels which have threatened those institutions with anti-trust action and make adequate financing most difficult. All in all, the draft report appears to us to be thorough and comprehensive, with the potential, assuming implementation of its recommendations, of reducing hospital construction costs. Sincerely yours Σ Decllivan John E. Sullivan APPENDIX VIII THE AMERICAN INSTITUTE OF ARCHITECTS October 17, 1972 Mr. James D. Martin Assistant Director, Man-Power & Welfare Division Dear Mr. Martin: The American Institute of Architects and the Committee on Architecture There are two areas in the report where the AIA must take issue with the Reuse of Design 1) With regard to the reuse of existing designs, the GAO report states "The concept appears sound and the benefits seem obvious," but no supporting data is supplied either in the report itself or in the enclosures to prove this statement. In fact, the data supplied suggest just the opposite conclusion, that the reuse of designs is a false economy in terms of life cycle costs. A large portion of hospital design problems involve renovation and expansion of existing buildings. These are unique problems which do not lend them 1785 MASSACHUSETTS AVENUE, N.W. 3 H ༞ · WASHINGTON, D. C. 20036 • (202) 265-3113 APPENDIX VIII Mr. James D. Martin October 17, 1972 selves to standardized design solutions. The GAO report states that The GAO report itself contradicts the concept of the reuse of plans when The inevitable conclusion is that there are no stock or standard plans for Total Concept 2) The report, in describing the "total concept approach," defines it as a "single developer undertaking the responsibility for planning, programming designing, financing, constructing and equiping a hospital under one financial transaction with the owner." While indicating that there are other means where |