Purpose
This bulletin is to inform hospitals of upcoming increases to your bed licensing fees as of November 2024.
Applicability/Scope
Hospital bed licensing fees will increase for both acute care and psychiatric hospitals as of November 1, 2024.
Recommendations
Review this bulletin and consider any preparations necessary for paying increased licensing fees beginning November 2024.
Overview
In April 2024, the Department of Health (DOH) initiated rulemaking to amend WAC 246-320-199 and more than double hospital bed licensing fees starting in November 2024. The final rule for the hospital licensing fee increase has now been released. As of November 1, 2024, licensing fees per bed will be as follows:
| Acute Care Hospitals | $505 |
| Critical Access Hospitals | $380 |
| Psychiatric Hospitals | $1700 |
Psychiatric Hospital licensing fees per bed will be reduced on November 1, 2025:
| Psychiatric Hospitals as of Nov 1, 2025 | $1450 |
WSHA advocacy and the Department’s justification for increased fees
Overall Increase in Complaints and Staffing Law Impacts
DOH primarily attributes the increase in acute care hospital licensing fees to an overall increase in complaints filed with the department and costs related to the new hospital staffing law (SB 5236, 2023). Because those costs were detailed in DOH’s fiscal note at the time the bill was passed, WSHA had less leverage to push back on those cost increases. Nevertheless, since the first draft of the rule, the Department responded to WSHA’s advocacy by reducing the estimated cost of the first year of the hospital staffing law by $1.1 million. This successfully reduced the proposed licensing fees for acute care hospitals.
Complaint Investigations
As noted above, according to DOH, rising costs include an increase in complaints against hospitals in the past several years, including a complaint backlog. These complaints are a mix of complaints from the public as well as from staff. Most of these complaints do not result in action against a hospital, but DOH must do their due diligence to investigate. The increase in complaint investigations is the source of most of the increased costs for psychiatric hospitals. The Department has detailed a rise in complaints against both acute care and psychiatric hospitals that require investigation. Psychiatric hospital fees are higher for the first year based on DOH assumptions that funds are necessary to clear the backlog of hospital complaints.
The Department has also detailed plans to hire several new employees to investigate complaints and process data, including an epidemiologist. WSHA expressed strong opposition to the plans for an epidemiologist, but the final rule continues to inappropriately attribute costs for the epidemiologist to acute care and psychiatric hospitals. WSHA is disappointed with this result.
Acute Care Prospective Payment System (PPS) vs Critical Access Hospitals (CAHs)
With respect to acute care hospitals, the final rule language indicates that critical access hospitals will be charged a lower licensing fee than PPS hospitals moving forward. Because our membership has expressed differing views on this issue, WSHA did not take a position on this differential fee between hospital types.
WSHA’s 2024 New Law Implementation Guide
Please visit WSHA’s new law implementation guide online. The Government Affairs team is hard at work preparing resources and information on the high priority bills that passed in 2024 to help members implement the new laws, as well as links to resources such as this bulletin. In addition, you will find the Government Affairs team’s schedule for release of upcoming resources on other laws and additional resources for implementation.
References
Final Rule (CR103)
Explanatory Statement from the Department of Health
WAC 246-320-199
