Defendant Methodist Hospital Supplemental Answers to Plaintiffs' First Set of Interrogatories

     [||3ceb3f67-b9dd-4fed-99a2-0b489249181f||] IN THE 

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

BERNICE TERRY, et al., 

Plaintiffs 

No. H 76-373 VS. 

METHODIST HOSPITAL OF GARY, INC., 

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Defendants 

RICHARD GORDON HATCHER, et al., 

Plaintiffs 

VS. No. H 77-154 

METHODIST HOSPITAL OF GARY, INC., 

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Defendants 

DEFENDANT METHODIST HOSPITAL OF GARY, INC. 
SUPPLEMENTAL ANSWERS TO PLAINTIFFS' FIRST SET OF INTERROGATORIES 
  

Comes now the defendant, Methodist Hospital of Gary, 
Inc., and files its Supplemental Answers to the plaintiffs’ 
first set of Interrogatories pursuant to the Federal Rules 
of Civil Procedure, Rule 33. 

57. Separately state the ratio of registered nurses, 
licensed practical nurses, nurses aides and student nurses 
to patients at Gary Methodist Hospital: 

(b) As of January 1, 1977; 
(c) As of January 1, 1976; 

{G) As OF January 1, 1975; 
(e) As of January 1, 1974; 

(f£) As of January 1, 1973; 
{g) As of January 1, 13570. 

Answer: 
ee. 

See Exhibit No. 57.  



  

58. Separately state the ratio of registered nurses, 
licensed practical nurses, nurses aides and student nurses 
to patients at Broadway Methodist Hospital: 

(a) As of the time these Interrogatories are answered; 
(b) As of January 1, 1977; 
{c) ‘As of January 1, 1975. 

Answer: 

See Exhibit No. 58 

6l. Separately state the ratio of social service staff 
“and volunteers to patients at Gary Methodist Hospital: 

(a) As of the time these Interrogatories are answered; 
(b) As Of January 1, 1977; 
{C) ‘As of January 1, 1975; 
(8d) As of January 1, 1975; 
(e) As of January 1, 1974; 
{(f) As of January 1, 19173: 
(9g) As of January 1, 1972; 
{h) As of January 1, 1971; and 
(1) As of January 1, 1970. 

Answer: 

See Exhibit No. 6l. 

62. Separately state the ratio of social service staff 
and volunteers to patients at Broadway Methodist Hospital: 

(a) As of the time these Interrogaties are answered; 
{b) - As of January 1, 1977: and 

(Cc) As of January 1, 1978. 

Answer: 

See Exhibit No. 62. 

68. State the following information for Gary Methodist 
Hospital for each year (either calendar year or fiscal year, 
but specify which) for the years 1977, 1976, 1975, 1974, 1973, 
1970, and 1965 for Gary Methodist Hospital and for the years 
1977, 1976 for Broadway Methodist Hospital: 

(a) the total number of inpatients and inpatient days, 
clinic patients and clinic visits, ambulatory care 
patients and patient visits, and emergency room 
patients and patient visits; 

(b) with respect to inpatients, for each inpatient service 
unit, the number of patients and patient days, by 
race, national origin and sex; by patient's home 
zip code, and by source of admission (physician 
referral, outpatient clinic, emergency room, neighbor- 
hood health facility, other), and by means of payment 
(private insurance, Medicare, Medicaid, Title V, 
self pay, free care, other); 

 



  

(c) 

(d) 

(e) 

(£) 

(9) 

with respect to outpatient clinic patients, for 
each outpatient clinic, the number of patients and 
(if different) patient visits, by race, national 
origin and sex, by patient's home zip code, and 
by means of payment. 

with respect to emergency room patients, the number 
of patients and (if different) patient visits, by 
race, national origin and sex, by means of payment 
and patient's home zip code. 

with respect to emergency room patients, the number 
admitted as inpatients; 

with respect to ambulatory patients, for each ambulatory 
service, the number of patients and (if different) 
patient visits by race, national origin and sex, 
by patient's zip code, and by means of payment; 

identify and attach copies of all studies, documents, 
and reports in which any of the above or comparable 
information for the specified years is set forth, 
and which Methodist Hospital considered and/or submitted 
to any governmental or regulatory body prior to 
or with reference to the construction of Broadway 
Methodist Hospital and the proposed expansion of 
Broadway Methodist Hospital. 

Answer: 

(a) Inpatients see 68(b)Y 
Inpatient days see 68(b). 
Clinic patients see 68(c)v 
Clinic visits see 68 (c), 
Emergency Room see 91 (c) 
Ambulatory care see 90 (f) 

(b) (c) See Exhibits 68(b) and (c) 

(d) 

{ec) 

(£) 

(9) 

As to mode of payment see Exhibit 68 (h)t~ 

See Answer to Interrogatory 91 (c)V 
NO records are kept of Emergency Room patients by 
race. With regard to mode of payment see Answer 
107 and Exhibit 68 (h)Y Records are kept of expected 
means of payment, but those records are not an. accurate 
method of determining actual means of payment. 
With respect to patient zip codes see Exhibit 681{c): 

See attached Exhibit 68 (b). 

See generally Exhibit 68(c) and Answer to Interroga- 
tory S0(f). 

The materials considered by Methodist Hospital in 
reaching its decisions to build the Broadway site and 
formulating the current broposals are generally 
the same materials utilized to answer this Interrogatory, 
i.e. patient medical records, summary sheets, 
some computer print-outs, a few patient logs kept 
on a sporadic basis by department heads and the 
general experience of various supervisory and 

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administrative personnel. The hospital has submitted 
fragmentary reports to the Department of Health, 
Education and Welfare's Office for Civil Rights 
in response to inquiries from that office. These 
reports have contained information concerning 
patient residence and race of individuals utilizing 
specific services provided by the hospital. These 
reports, if not previously produced by H.E.W. 
will be made available to the plaintiffs pursuant 
to plaintiffs' Request for Production of Documents. 

76. List all inpatient, outpatient clinic, ambulatory, 
&o emergency room, laboratory departments and services provided 

by JBeeoedwey Methodist Hospital. State whether, how and 
why these services have changed since the opening of Broadway 
Methodist Hospital. 

Answer: 

See Exhibit No. 76. 

77. List all inpatients, outpatient clinic, ambulatory, 
emergency room, laboratory departments and services provided 
by Gary Methodist Hospital. State whether, how and why 
these services have changed: 

Answer: 

See Exhibit No. 76. 

84. For each inpatient service unit or department 
at Gary Methodist Hospital and Broadway Methodist, separately 
state: : 

(a) the number of patients and patient days for the 
Vears 1977, 1976, 1975, 1974 and 1973; 

(b) the major equipment and age of such equipment 
used in connection with the service: 

(c) during any one rotation the number of residents, 
interns and externs assigned to the service; 

(d) during any one rotation the number of registered 
nurses, licensed practical nurses and nurses aides 
assigned to the service; 

(e) the physicians (not including those in training) 
by specialty and name who admitted their private 
patients to the service unit during the years 
1976, 1975 and 1974, and the number of patients 
thus admitted; and 

(£) the physicians (not including those in training) 
by specialty and name, who were assigned or assumed 
responsibility for patients without private physicians, 
or patients admitted from the outpatient clinics, 
and the number of patients admitted. 

Answer: 

See Exhibit No. 84. 

 



  

90. For each ambulatory service department at Gary 
Methodist Hospital and Broadway Methodist Hospital separately 
state: : 

(a) the days and hours of operation for the years 
1977,-1976, 1975, 1974 and-1973; 

(b) the procedures and treatment available in each 
department; 

(c) the major equipment and age of such equipment 
used in connection with the service; 

(d) the physicians (Not including those in training) 
assigned to each department (identifying by name 
and specialty and hours spent in the claims on 
a weekly basis during the most recent complete 
two fiscal years and whether employed by the hospital 
or affiliated via a grant of staff privileges); 

(e) during any one rotation the number of residents, 
interns, and externs assigned to the department; 

(£) the number of visits during the most recent complete 
two fiscal years.; : 

(g) the physician in charge of the overall operation 
of the department and the hours he (she) spent 
on a weekly basis during the most recent compete 
two fiscal years. 

Answer: 

See Exhibit No. 90. 

91. For each emergency room at Gary Methodist Hospital 
and Broadway Methodist Hospital, separately state: 

(a) all services, procedures, and treatment available; 
(b) the major equipment and age of such equipment 

used in connection with the service; 
(c) the number of patient visits during the years 

1977, 1976, 1975, 1974 and 1973; 
(d) the physicians (not including those in training) 

assigned during each shift (identifying by name, 
number, and specialty, and hours of responsibility 
whether employed by the hospital or affiliated 
via a grant of staff privileges); and 

(e) during any one rotation the number of residents, 
interns, and externs each shift. 

Answer: 

The hospital does not employ residents, interns and 
externs in the emergency rooms. 
See Exhibit No. 91, 

HODGES, DAVIS, GRUENBERG, COMPTON & SAYERS 
Hm DEFENDANT, 
METHODI | fe AL 0 

{ /| a > § 

BY , RN | / ; A \ ~ / V oy 

\ J hb ll ¥ 

  

  

' WILLIAM B. DAVIS 
5525 Broadway 

- Gary, Indiana 46410 
Ph. 981-2557 

STATE OF INDIANA ) 

}SS: 

COUNTY OF LAKE ) 

Roald B. Glesne, being first duly sworn upon his oath, 

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deposes and says: 

That he is the Administrator of the Methodist Hospital 
of Gary, Inc.; that the above answers to Interrogatories 
were prepared at his specific direction and request on behalf 
of the said Defendant Corporation; that he has read the 
said answers and that they are a and Corgect to the best 
of his knowledge and belief 

i ol 77 2/5, = FN, 

Foald B. Glésng 
  

Subscribed and sworn to before me, a Notary Public 
in and for said County and State, this 7th day of October, 
1877. \ NL \ 

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\ \ A \ \ EN A » 
| | h i B N f | \ \ \ \ \ y \ he ( 

| | Re & 
  

William B. Davis, SOT Public 

My Commission Expires: 

July 7,.1978 [||3ceb3f67-b9dd-4fed-99a2-0b489249181f||]