Week Eleven Takeaways

Date: February 7, 2025

We continue to receive questions about whether we are the "concerned Oregonians" that submitted public comment #91 (page 52). While we are concerned, we did not submit this comment, though we do agree with what was outlined in their comment. We will continue to keep subscribers informed of any future comment from the UE and are currently working on letters to our elected officials on a federal level as well as both Governors. As public leaders, their reputation and prospects for reelection are incumbent on ensuring they are listening to the voices of the voters, our voices. They have not yet provided a public perspective on this transaction, like they have with others, and we would like to understand why they are silent when there are so many public comments.

If approved, the consequences of OHSU acquiring Legacy Health will become apparent within the next year. For the community, those consequences are very real when we talk about the cost of care and ease of accessing care. One of the most compelling concerns for access is the 74,000 people covered by UnitedHealthcare at risk for not being able to seek care at OHSU beginning April 1. According to UHC, OHSU’s proposal would make them “the most expensive health system in our Medicare Advantage network in the Portland metro area.” If Legacy becomes OHSU, when Legacy’s current contract ends, its six hospitals would no longer be an option for these patients. This is one example of why health care competition in local markets is important and beneficial to communities. Also, OHSU continues to say that they will not increase cost, but have proposed a 36% cost increase over two years. 

Last week, OHSU submitted a public comment on their own transaction titled OHSU + Legacy Health: An Urgent Case for Integration in Response to Public Comments. Contrary to its title, it is not a response. Rather than address the real concerns raised by the public comments, it largely consists of the same information from the transaction filing to the Oregon Health Authority, including outdated Legacy financials and reiterations of OHSU’s status as a government organization. This comment was submitted by three OHSU executive leaders and while it speaks on behalf of Legacy, there is no representation from Legacy. 

On page 12, OHSU addresses other public comments. The section begins and ends by dismissing the validity of public concerns. Rereading this reminded us of a popular social media trend where friends or family confess something about themselves. Instead of reacting, the listeners say "We listen and we don’t judge.” Their facial expressions humorously tell the story. While the trend is meant to be lighthearted, its core message is about respecting someone’s feelings, values and experiences as valid, even if they are different from your own. Healthcare is deeply personal, and the tone of OHSU’s submission does not reflect the empathy we expect from leaders entrusted with caring for people in vulnerable moments of life. Nor does it truly seem to address real issues like those highlighted in the “concerned Oregonians” comment, like commitment to health equity. Instead, it seems like a direct rebuttal to the Brown University comment to diminish the main ideas raised in that paper. 

For example, one of the points the OHSU leaders raised is their disagreement with comparing this deal to national studies on similar transactions. They state: “One comment claims that the OHSU-Legacy integration will not improve and might even worsen access problems in Oregon, especially in primary care. This conclusion appears to rely on national studies about health care mergers rather than the facts of the OHSU-Legacy integration proposal.” As an academic health center, it’s difficult to understand the logic behind disregarding national research. Without integrating insights from previous examples, both successful and not, this deal risks repeating past mistakes rather than improving the system for Oregonians. This is especially critical for primary care, which serves as the first point of contact for meeting people’s health needs. While OHSU’s filing outlines broad access goals, it offers no strategy or pathway for achieving them. Now is not the time to take an irreversible leap of faith without a clear plan. 

Lastly, in recent news, the OHA announced the members of the community review board responsible for making a recommendation about whether they should approve a deal to proceed as planned, apply conditions to the deal, or disapprove the deal. The state may retain outside advisors, but there has been no disclosure on who has been retained or their methodology to review the transaction in accordance with HCMO and federal antitrust laws. Community review board meetings are virtual and open to the public, and meeting information and materials are located on the OHSU-Legacy transaction page. Our hope is the community review board will have access to the public comments, hear our collective concerns and raise their own. Please continue to share your comments and encourage your friends and family members to share theirs as well.

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