1
HEALTH FACILITIES COMMISSION
JANUARY 25, 2023
APPLICATION REVIEW
NAME OF PROJECT: CareMax Pharmacy of Loudon, Inc. (Middle)
PROJECT NUMBER: CN2210-040
ADDRESS: 601 Grassmere Park, Suite 19A
Nashville (Davidson County), TN 37211
LEGAL OWNER: CareMax Pharmacy of Loudon, Inc.
601 Grassmere Park, Suite 19A
Nashville (Davidson County), TN 37211
OPERATING ENTITY: N/A
CONTACT PERSON: Daniel Carter, Ascendient Healthcare Advisors
(919) 226-1705
DATE FILED: October 31, 2022
PROJECT COST: $155,000
PURPOSE FOR FILING: Establishment of a home care organization and the initiation of
home health services.
Staff Review
Note to Commission members: This staff review is an analysis of the statutory criteria
of Need, Consumer Advantage Attributed to Competition, and Quality Standards,
including data verification of the original application and, if applicable, supplemental
responses submitted by the applicant. Any Health Facilities Commission Staff
comments will be presented as a "Note to Commission members" in bold italic.
PROJECT DESCRIPTION:
CAREMAX PHARMACY OF LOUDON, INC. (MIDDLE) CN2210-040
JANUARY 25, 2023
PAGE | 1
, 2
This application is for the establishment of a home care organization to initiate and
provide home health services limited to infusion services. The 12-county service area
counties include Cheatham, Davidson, Dickson, Macon, Maury, Montgomery, Robertson,
Rutherford, Sumner, Trousdale, Williamson and Wilson Counties. The new home health
organization’s office will be located at 601 Grassmere Park, Suite 19A, Nashville
(Davidson County), Tennessee 37211.
Executive Summary
• If approved, the applicant projects the proposed project will open for service in
March 2023.
• The applicant is proposing to establish a home health agency limited to home
infusion services in Middle Tennessee to serve patients of its existing pharmacy
and infusion center businesses based in Nashville (Davidson County) and
Hendersonville (Sumner County) Tennessee.
• The applicant’s affiliates currently provide pharmacy-related services, including
outpatient infusion centers, specialty pharmacy, and home infusion therapy in 9
states including Tennessee. The applicant states that its affiliated entities have
experienced difficulty in meeting the in-home infusion therapy needs of patients in
the service area for specific types of infusion services including anti-infectives,
cardiac medications, nutritional support, immunoglobulin (IG), and specialty
medications. This is due to the inability of existing home health providers to
deliver these type of services because of limitations related to staff availability and
payer source considerations. The applicant will not provide
oncology/chemotherapy infusions in the home.
• Please see application Item 1E. on page 7 for the applicant’s executive summary
overview that includes project description, ownership, service area, existing similar
service providers, project cost, and staffing.
Note to Commission Members: The applicant has also filed a pending home health
infusion therapy companion application, CareMax of Pharmacy of Loudon, Inc. (East),
CN2210-039 which will also be heard at the January 25, 2023 Commission Meeting. The
applicant’s home office will be located will be located at 418 South Gay Street, Suite 203,
Knoxville (Knox County), TN 37902. The proposed service area includes Anderson,
Bledsoe, Blount, Bradley, Campbell, Claiborne, Cocke, Cumberland, Fentress, Grainger,
Hamblen, Hamilton, Jefferson, Knox, Loudon, Marion, McMinn, Meigs, Monroe, Rhea,
Roane, Sequatchie, Sevier and Union Counties.
Consent Calendar: □ Yes √ No
• Executive Director’s Consent Memo Attached: □ Yes √ Not applicable
Facility Information
CAREMAX PHARMACY OF LOUDON, INC. (MIDDLE) CN2210-040
JANUARY 25, 2023
PAGE | 2
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• The 184 square foot project office site will be a home health nursing office colocated
with the Paragon Healthcare Nashville pharmacy office. The property is being sub-
leased to the applicant, CareMax Pharmacy of Loudon, Inc., through its owner,
Paragon Healthcare, Inc. through the landlord, EP Grassmere LLC, for an initial
seven-year term beginning July 1, 2021. See Attachment 9.A. Lease Agreement and
Sub-Lease Agreement.
• The applicant is not proposing to establish any branch offices.
Ownership
• The applicant, is owned by Pathwrite, Inc., which is owned by Paragon Healthcare,
Inc., which is owned by PHI Parent, LLC, which is ultimately owned by PHI Topco,
LLC.
Project Cost Chart
• The total project cost is $155,000. Of this amount, the highest line-item costs of the
project are Legal, Administrative, Consultant Fees Costs ($125,000), and Facility
Lease Costs ($23,000).
• Please see the Project Cost Chart on page 11 of the application.
NEED
The applicant provided the following supporting the need for the proposed project:
• The inability of the applicant to service its patient base through referrals to
traditional home health agencies to serve home infusion therapy patients due to
limitations with staff experience and training.
• The existing patient base of the applicant includes individuals who have recently
been discharged from an acute care setting and are unable to receive home based
infusion services in a timely fashion.
• The availability of home infusion services will reduce or eliminate travel time and
expenses for patients who require infusion services.
• The applicant cites the fact that traditional home health agencies are often not
reimbursed for the nursing services associated with home infusion services at a
level that covers the cost of care and are therefore not willing to deliver these types
of specialized services.
(For applicant discussion, see the Original Application, Page 9)
SERVICE SPECIFIC CRITERIA AND STANDARD REVIEW
Home Health Services:
All applicable criteria and standards were met except for the following:
CAREMAX PHARMACY OF LOUDON, INC. (MIDDLE) CN2210-040
JANUARY 25, 2023
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Did not meet the standard of #1. Determination of Need “In a given county, 1.5
percent of the total population will be considered as the need estimate for home
health services in that county. This 1.5 percent formula will be applied as a
general guideline, as a means of comparison within the proposed Service Area.”
This project proposes to initiate home health services in a twelve-county service area, which
cumulatively show a surplus of (9,776) home health admissions according to the standard of
(1.5%) of the total population of the counties included in the project service area. The three
counties included in the service area which show the largest surplus are the following:
Davidson County (2,844), Sumner County (1,512), and Wilson County (1,432). See
Attachment 1.N.3, Home Health Services Standards and Criteria, Pages 1 -4.
Note to Commission Members: The applicant cites multiple concerns with the existing
home health service need formula including the following:
• The need formula is not specific to the type of home health service being proposed
by the applicant – home infusion therapy services, which are more complex and
specialized than traditional home health services, and is therefore not accurately
representative of need for the project in the service area.
• The applicant states that (1.5%) rate for the service area population prescribed by
the need standard is exceeded by the actual use rate if the services area in 2021
(1.9%).
Please see attached for a full listing of the criteria and standards and the applicant’s
responses.
Service Area Demographics
• The proposed service area includes Cheatham, Davidson, Dickson, Macon, Maury,
Montgomery, Robertson, Rutherford, Sumner, Trousdale, Williamson, and Wilson
Counties. (see Attachment 2N for a county level map).
• The target population is the adult population age 65 and younger. (See Attachment
3NR for more demographic details.)
2022 Population 2026 Population % Change TennCare
Total Under 65 Total Under 65 Total Under %
65
Service Area 2,215,104 1,642,287 2,346,478 1,989,983 5.9% 21.2% 19.3%
Tennessee Total 6,997,493 5,743,164 7,203,404 5,826,949 2.9% 1.4% 24.4%
Source: The University of Tennessee Center for Business and Economic Research Population Projection Data Files, Reassembled by the Tennessee
Department of Health, Division of Policy, Planning and Assessment, Office of Health Statistics.
• The proposed service area projects a 4-year growth rate (2022-2026) among
residents aged 65 and under of (21.2%) which is higher than the statewide rate of
CAREMAX PHARMACY OF LOUDON, INC. (MIDDLE) CN2210-040
JANUARY 25, 2023
PAGE | 4
HEALTH FACILITIES COMMISSION
JANUARY 25, 2023
APPLICATION REVIEW
NAME OF PROJECT: CareMax Pharmacy of Loudon, Inc. (Middle)
PROJECT NUMBER: CN2210-040
ADDRESS: 601 Grassmere Park, Suite 19A
Nashville (Davidson County), TN 37211
LEGAL OWNER: CareMax Pharmacy of Loudon, Inc.
601 Grassmere Park, Suite 19A
Nashville (Davidson County), TN 37211
OPERATING ENTITY: N/A
CONTACT PERSON: Daniel Carter, Ascendient Healthcare Advisors
(919) 226-1705
DATE FILED: October 31, 2022
PROJECT COST: $155,000
PURPOSE FOR FILING: Establishment of a home care organization and the initiation of
home health services.
Staff Review
Note to Commission members: This staff review is an analysis of the statutory criteria
of Need, Consumer Advantage Attributed to Competition, and Quality Standards,
including data verification of the original application and, if applicable, supplemental
responses submitted by the applicant. Any Health Facilities Commission Staff
comments will be presented as a "Note to Commission members" in bold italic.
PROJECT DESCRIPTION:
CAREMAX PHARMACY OF LOUDON, INC. (MIDDLE) CN2210-040
JANUARY 25, 2023
PAGE | 1
, 2
This application is for the establishment of a home care organization to initiate and
provide home health services limited to infusion services. The 12-county service area
counties include Cheatham, Davidson, Dickson, Macon, Maury, Montgomery, Robertson,
Rutherford, Sumner, Trousdale, Williamson and Wilson Counties. The new home health
organization’s office will be located at 601 Grassmere Park, Suite 19A, Nashville
(Davidson County), Tennessee 37211.
Executive Summary
• If approved, the applicant projects the proposed project will open for service in
March 2023.
• The applicant is proposing to establish a home health agency limited to home
infusion services in Middle Tennessee to serve patients of its existing pharmacy
and infusion center businesses based in Nashville (Davidson County) and
Hendersonville (Sumner County) Tennessee.
• The applicant’s affiliates currently provide pharmacy-related services, including
outpatient infusion centers, specialty pharmacy, and home infusion therapy in 9
states including Tennessee. The applicant states that its affiliated entities have
experienced difficulty in meeting the in-home infusion therapy needs of patients in
the service area for specific types of infusion services including anti-infectives,
cardiac medications, nutritional support, immunoglobulin (IG), and specialty
medications. This is due to the inability of existing home health providers to
deliver these type of services because of limitations related to staff availability and
payer source considerations. The applicant will not provide
oncology/chemotherapy infusions in the home.
• Please see application Item 1E. on page 7 for the applicant’s executive summary
overview that includes project description, ownership, service area, existing similar
service providers, project cost, and staffing.
Note to Commission Members: The applicant has also filed a pending home health
infusion therapy companion application, CareMax of Pharmacy of Loudon, Inc. (East),
CN2210-039 which will also be heard at the January 25, 2023 Commission Meeting. The
applicant’s home office will be located will be located at 418 South Gay Street, Suite 203,
Knoxville (Knox County), TN 37902. The proposed service area includes Anderson,
Bledsoe, Blount, Bradley, Campbell, Claiborne, Cocke, Cumberland, Fentress, Grainger,
Hamblen, Hamilton, Jefferson, Knox, Loudon, Marion, McMinn, Meigs, Monroe, Rhea,
Roane, Sequatchie, Sevier and Union Counties.
Consent Calendar: □ Yes √ No
• Executive Director’s Consent Memo Attached: □ Yes √ Not applicable
Facility Information
CAREMAX PHARMACY OF LOUDON, INC. (MIDDLE) CN2210-040
JANUARY 25, 2023
PAGE | 2
, 3
• The 184 square foot project office site will be a home health nursing office colocated
with the Paragon Healthcare Nashville pharmacy office. The property is being sub-
leased to the applicant, CareMax Pharmacy of Loudon, Inc., through its owner,
Paragon Healthcare, Inc. through the landlord, EP Grassmere LLC, for an initial
seven-year term beginning July 1, 2021. See Attachment 9.A. Lease Agreement and
Sub-Lease Agreement.
• The applicant is not proposing to establish any branch offices.
Ownership
• The applicant, is owned by Pathwrite, Inc., which is owned by Paragon Healthcare,
Inc., which is owned by PHI Parent, LLC, which is ultimately owned by PHI Topco,
LLC.
Project Cost Chart
• The total project cost is $155,000. Of this amount, the highest line-item costs of the
project are Legal, Administrative, Consultant Fees Costs ($125,000), and Facility
Lease Costs ($23,000).
• Please see the Project Cost Chart on page 11 of the application.
NEED
The applicant provided the following supporting the need for the proposed project:
• The inability of the applicant to service its patient base through referrals to
traditional home health agencies to serve home infusion therapy patients due to
limitations with staff experience and training.
• The existing patient base of the applicant includes individuals who have recently
been discharged from an acute care setting and are unable to receive home based
infusion services in a timely fashion.
• The availability of home infusion services will reduce or eliminate travel time and
expenses for patients who require infusion services.
• The applicant cites the fact that traditional home health agencies are often not
reimbursed for the nursing services associated with home infusion services at a
level that covers the cost of care and are therefore not willing to deliver these types
of specialized services.
(For applicant discussion, see the Original Application, Page 9)
SERVICE SPECIFIC CRITERIA AND STANDARD REVIEW
Home Health Services:
All applicable criteria and standards were met except for the following:
CAREMAX PHARMACY OF LOUDON, INC. (MIDDLE) CN2210-040
JANUARY 25, 2023
PAGE | 3
, 4
Did not meet the standard of #1. Determination of Need “In a given county, 1.5
percent of the total population will be considered as the need estimate for home
health services in that county. This 1.5 percent formula will be applied as a
general guideline, as a means of comparison within the proposed Service Area.”
This project proposes to initiate home health services in a twelve-county service area, which
cumulatively show a surplus of (9,776) home health admissions according to the standard of
(1.5%) of the total population of the counties included in the project service area. The three
counties included in the service area which show the largest surplus are the following:
Davidson County (2,844), Sumner County (1,512), and Wilson County (1,432). See
Attachment 1.N.3, Home Health Services Standards and Criteria, Pages 1 -4.
Note to Commission Members: The applicant cites multiple concerns with the existing
home health service need formula including the following:
• The need formula is not specific to the type of home health service being proposed
by the applicant – home infusion therapy services, which are more complex and
specialized than traditional home health services, and is therefore not accurately
representative of need for the project in the service area.
• The applicant states that (1.5%) rate for the service area population prescribed by
the need standard is exceeded by the actual use rate if the services area in 2021
(1.9%).
Please see attached for a full listing of the criteria and standards and the applicant’s
responses.
Service Area Demographics
• The proposed service area includes Cheatham, Davidson, Dickson, Macon, Maury,
Montgomery, Robertson, Rutherford, Sumner, Trousdale, Williamson, and Wilson
Counties. (see Attachment 2N for a county level map).
• The target population is the adult population age 65 and younger. (See Attachment
3NR for more demographic details.)
2022 Population 2026 Population % Change TennCare
Total Under 65 Total Under 65 Total Under %
65
Service Area 2,215,104 1,642,287 2,346,478 1,989,983 5.9% 21.2% 19.3%
Tennessee Total 6,997,493 5,743,164 7,203,404 5,826,949 2.9% 1.4% 24.4%
Source: The University of Tennessee Center for Business and Economic Research Population Projection Data Files, Reassembled by the Tennessee
Department of Health, Division of Policy, Planning and Assessment, Office of Health Statistics.
• The proposed service area projects a 4-year growth rate (2022-2026) among
residents aged 65 and under of (21.2%) which is higher than the statewide rate of
CAREMAX PHARMACY OF LOUDON, INC. (MIDDLE) CN2210-040
JANUARY 25, 2023
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