Defendant Methodist Hospital of Gary, Inc. Answers to Plaintiffs' First Set of Interrogatories

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IN fHE 

  

UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

BERNICE TERRY, et al., ) 

Plaintiffs : 

vs, ) No..H 76~373 

METHODIST HOSPITAL OF GARY, INC., 

et al., ) 

Defendants | 

RICHARD GORDON HATCHER, et al., ) 

Plaintiffs ; 

VS. ) NO, H 71-154 

METHODIST HOSPITAL OF GARY, INC., 

et al., ) 

Defendants : 

DEFENDANT METHODIST HOSPITAL OF GARY, INC. 

ANSWERS TO PLAINTIFFS' FIRST SET OF INTERROGATORIES 
  

Comzs now the defendant Methodist Hospital of Gary, Inc. 
and files Answers to Plaintiffs' First Set of Interrogatories. 
The source of these answers is the Hospital Administrative 
Staff. To the extent that these answers are incomplete, ad- 
ditional information will be supplied if available. 

The defendant 1s well aware of its duty under the Federal 
Rules of Civil Procedure to supplement the answers to these 
Interrogatories. Defendant understands that responsibility 
and duty and intends to comply with the letter and spirit 
Of the Rules. Defendant points out to the Court that it has 
expended a good deal of time and money in the preparation 
of these answers. The answers themselves are as accurate 
as the Hospital could possibly make them in view of the plethora 
of records and documents examined by the defendant in the 
preparation of these answers. 

  

  

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1. Describe the complete organizational structure 
of Methodist Hospital, specifying all officers, boards of 
directors and trustees, divisions, sections, committees, 
offices, units and all other organizational substructures, 
including the medical staff, any volunteer and any fund- 

raising organization, divisions, committees or units of Methodist 
Hospital. Include whether, how and why the organizational 
structure has changed since 1965, and indicate for all organizational 
substructures where they pertain to, have authority over, 
or otherwise operate with respect to Gary Methodist Hospital, 
Or hoth. 

Answer: 

Methodist Hospital of Gary, Inc. is one corporation, 
having one board of directors, one administrative staff 

and one medical staff. Attached as Exhibit 1-aAYis 

the "Manual of Organization" effective April, 1977. 
Attached as Exhibit 1-B is the "Manual of Organization, 
as Revised May 20, 1965." To determine the changes 
in the organizational structure a comparison of the 
two may be made. The organization charts illustrate 
the authority of the line deparments over the Gary 
and Broadway facilities. If no specific designation 
is set forth, the department or division applies to 

both facilities. 

2. Describe briefly, but completely, the functions 

of the various levels of each organizational substructure 
or unit specified in Interrogatory 1 above; the scope of 
each function specified; whether the various levels function 
with respect to part or to all of the hospitals operated 
by Methodist Hospital, and whether, how and why each function 

has changed since 1965. 

Answer: 

All the units of the structure of the Methodist Hospital 
of Garv, Inc. ate applicable to both hospital facilities. 
The board of directors, the medical staff, the hospital 
administrative staff and the volunteer auxiliary have juris- 
diction over both hospital facilities, and there is 
no division of responsibility structurally between 
the two hospital facilities. ‘There are a few excep- 
tions, which are clearly set forth in the Organization 
Manual described in the answer to Intercogatory No. 1. 

The changes in scope and function, since 19565, are 

as indicated by a comparison of the Manual of Organization 
which was effective in 1965 and the current Manual 

of Organization. 

  
  

 



  

3. Describe all laws, statutes, regulations or other 

authority pursuant to which Methodist Hospital is organized 
or carries out its functions; all governmental agencies, 
organizations or other bodies which regulate, supervise, 
monitor or otherwise govern the organizational structure 
of Methodist Hospital specified in Interrogatory 1 above, 
and functions of Methodist Hospital specified in Interrogatory 2. 

Answer: 

A description of laws, statutes and regulations and 
names of governmental agencies applicable to the organization 
and operation of Methodist Hospital of Gary, Inc. are 
equally available to the plaintiff by research into 
the various laws applicable thereto. 

The existence of the Hospital Corporation 1s more specifically 
described in the answer to Interrogatory No. 4. 

The relationship of the Hospital with the United Methodist 
Church is as described in the answer to Interrogatory 

No. 4. 

The organizations which monitor certain activities 
of the Hospital for accreditation purposes are as described" 
in the answer to Interrogatories Nos. 86 and 87. 

4. Describe all incorporation, charter, commission, 
regulation, by-law or other documents which state the organization 
of Methodist Hospital specified in Interrogatory 1 above. 

Answer: 

The Defendant, Methodist Hospital of Gary, Inc. 
was issued a Corporate Charter by James Tucker, Secretary 
of State of the State of Indiana. The Charter was 
issued March 27, 1941, upon the filing of the Articles 

of Incorporation under and in accordance with the provisions 
of an Act entitled "An Act concerning private corporation 
not-for-profit and declaring an emergency" approved 

March 6, 1923. 

The Articles state that the name of the corpora- 
tion shall be "The Methodist Hospital of Gary, Inc." 

and describe the objects of the corporation as follows: 

A) To acquire, own, equip, maintain, finance, 
improve, construct and operate not-for-profit 
a hospital and additions thereto for treatment 
of sick, wounded, deformed and injured persons 
and maternity patients, and 

  

 



  

B) Not-for-profit, to acquire, own, equip, maintain, 

finance, improve, construct and operate a | 

school for training and education of nurses, 
nurses' homes and additions to such school 
or homes; 

C) To acquire, own, equip, maintain, finance, 
improve, construct and operate not-for-profit 
such lands and buildings and improvements 
as may be necessary for the proper carrying 
out of the purposes herein expressed. 

D) To permit in said hospital and additions 
thereto medical research and the practice 
by qualified physicians and surgeons of their 
professions; 

E) To dispense relief and charity to the poor 
and destitute; 

The Articles further provide for a Board of Directors 
of 36 members; not less than 21 of said members shall 
be members in good standing of the Methodist Church. 
All nominations of Board Members were submitted to 
the resident Bishop of the Methodist Church, and if 
he shall approve them, they shall be submitted to the 
Annual Meeting of the Northwest Indiana Conference 
of the Methodist Church, and it shall elect them. 
Thereafter, 12 members of the Board would be nominated 
and elected annually in accordance with the above procedure. 
The Articles further identify the first Board of Directors 
and Incorporators. 

On November 4, 1966, the Hospital Corporation 
filed Articles of Amendment with the Secretary of State 
and a Certificate of Amendment was issued on said date 
by John D. Bottorff, Indiana Secretary of State. 

Said Amendment provided as follows, to-wit: 

"Beginning in 1967, as vacancies occur on 
such Board through the expiration of the 
respective terms of members who are now serving 
on such Board, the Board of Directors of 
this corporation shall be named and designated 
in accordance with the following provisions: 

i. Not less than 21 members of the Board 
of Directors shall be members in good 
standing of a Methodist Church in the 
area of the Northwest Indiana Conference 

or a minister affiliated with a church 
in this conference area. 

2. Not less than 3 members of the Board 

of Directors shall be Negroes. 

  

 



  

3. The Bishop of the Indiana area of the 
Methodist Church, the District Superintendent 
of the Calumet District of the Northwest 
Indiana Conference of the Methodist 
Church and the President of the Women's 
Auxiliary of the Methodist Hospital 
of Gary, Inc. shall be ex-officio members 
of the Board of Directors of this corporation. 

4. The Northwest Indiana Conference of 
the Methodist Church shall each year, 
at the Annual Conference, elect three 
members to the Board of Directors of 
this corporation, with the further proviso, 
however, that at least one of the directors 
so chosen shall be a layman who shall 
be a resident of the Calumet District 
of the Northwest Indiana Conference 
of the Methodist Church. 

Prior to the meeting of the Board of Directors 
of this corporation in April, 1967, and in each year 
thereafter, the President shall appoint a Nominating 
Committee consisting of five members of the Board of 
Directors. 

At the April meeting each year of the Board of 
Directors, the Nominating Committee shall place in 
nomination nominees for the officers of the Board of 
Directors and for membership on the Executive Committee. 

Such Nominating Committee shall likewise nominate 
each year, beginning in 1967, eight persons for membership 
on the Board of Directors to serve for a term of 3 
years succeeding the members whose terms expire in 
the year of such election. 

At the annual meeting of the corporation in July of each 
year, the Boad of Directors shall consider the nominations 
of the Nominating Committee for the officers of the 
Board for membership on the Executive Committee for 
the eight members on the Board of Directors. At such 
meeting, additional nominations for such offices may 
be received and considered. Such meeting shall then 
proceed to elect officers of the Board and members 
of the Executive Committee, all of whom shall serve 
until the next annual meeting. The Board shall also 
elect eight persons to membership on the Board of Directors, 
said persons to serve for a period of three years. 
The persons so elected shall take office immediatley 
upon being elected. The terms of the persons elected 
for membership on the Board of Directors by the Northwest 
Indiana Confernece shall likewise begin at the July 
meeting of each year of the Board of Directors. In 
case of a vacancy on the Board of Directors, the Board 
of Directors shall fill such vacancy and the person 
elected to fill such vacancy shall serve for the unexpired 
term of the member to whose office he was elected.” 

The Hospital Corporations By-Laws were revised 
in 1977 and further revisions are contemplated to comply 
with the Standards of the Joint Commission for Accreditation 
of Hospitals to be consistent with Medical Staff By- 

Laws recently revised. 

  

 



  

Medical Staff By-Laws were recently revised and 

adopted by the Medical Staff on the 12th day of January, 

1977, and adopted by the Board of Directors on February 28, 

1977. 

The Hospital Corporation likewise has instituted 

rules and regulations governing Medical Staff operations 

which have been revised and adopted on January 12, 

1977, by the Medical Staff and adopted by the Board 

of Directors on February 23, 1977. 

5. With reference to the organizational structure 

set forth in the answers to Interrogatories 1 and 2, state: 

a) name, position, level or title, race, national 

origin, sex, term or length of tenure Of the head 

of each office, board, division, section,. committee, 

unit or other substructure (hereinafter referred 

to as division") identified in the answer to 

Interrogatory 1; 

b) the specific responsibility or function assigned 

to each head identified in the answer to Interrogatory, 

5(a):; whether the responsibility or function assigned 

pertains to Gary Methodist Hospital, to Broadway 

Methodist Hospital, or to both hospitals; and 

whether how, and why each function or responsibility 

has changed since 1965; 

c) "the [irstatime, if any, such office job or other 

position was held by a black person. 

Answer: 

See Exhibit 5. 

  

   



  

6. Identify each position specified in Interrogatories 1 and 

5 in ascending order of responsibility in the Methodist 

Hospital hierarchy, indicating for each position the specific 

organizational unit(s) in which it is placed. 

Answer: 

The ascending order of responsibility of the organizational 

structure of the Hospital Corporation is as illustrated 

in the Manual of Organization set forth in the answer 

+0 Interrogatory No. 1, Exhibit l1-A. 

7. Describe the complete organizational structure 

of Gary specifying all offices, units, committees, divisions 

and all other organizational substructures. Include whether, 

how and why the organizational structure of Gary Methodist 

Hospital has changed since 1965. 

Answer: 

See answer to Interrogatory No. 1. 

8. Describe the complete organizational structure 

of Broadway Methodist Hospital, specifying all officers, 

units, committees, divisions and all other organizational 

substructures. Include the dates on which all organizational 

substructures at Broadway Methodist Hospital were conveived, 

organized and put into operation, and whether, how and why 

the structure has changed since the dates they were conceived. 

Answer: 

The organizational structure of the Hospital Corporation 

was merely enlarged to include the Broadway facility. 

To the extent that this was done, no specific date 

can at this time be assigned to it. The planning for 

the opening and operation of the Broadway facility 

was accomplished in the years 1974, 1975 and 1976. 

The Broadway facility opened on December 29, 1975. 

No changes in structure have since taken place regarding 

the Broadway facility as the organizational structure 

of the Hospital was merely enlarged and extended to 

include the Broadway facility. 

  

 



  

9. With respect to the organizational structure. of 

Gary Methodist Hospital set forth in the answer to Interrogatory 7, 
state: 

(a) the name, position, level or title, race, national 

origin, sex, term or length of tenure, and any 
other employment affiliation of the head of each 
office, department, unit, committee, division, 
and all other substructures. 

(b) the date that each person identified in the answer 
to Interrogatory 9(a) assumed his or her position; 

(c) the name, race, national origin, sex and term 
or length of employment of the predecessor of 
each person identified in the answers to Interrogatory 
9(a); 

(d) the specific responsibility or function assigned 

to each person identified in the answers to Interrogatory 
9(a); and whether, how and why each function or 
responsibility of the person identified in the 
answer to Interrogatory 9(a) has changed. 

Answer: 

See answer to Interrogatory 5. 

  

 



  

10. With respect to the organizational structure of Broadway 

Methodist Hospital set forth in the answer to Interrogatory 

8, state: 

(a) the name, position, level or title, race, national 
origin, sex, term or length of tenure, and any 
other employment affiliation of the head of each 
office, department, unit, committee, division 
and all other substructures; 

(b) the date that each person identified in the answer 

to Interrogatory 10(a) assumed his or her position; 

(c) the name, race, national origin, sex and term 
or length of employment of the predecessor of 
each person identified in the answers to Interrogatory 

10(a). 

(d) the specific responsibility or function assigned 
to each person identified in the answers to Inter- 
rogatory 10(a); and whether, how and why each 

function or repsonsibility of the person identified 
in the answer to Interrogatory 10(a) has changed. 

Answer: : 

See answer to Interrogatory 5. 

  

 



LV 

  

11. List the name, residence, occupation, race, national 
origin and sex of cach member of the Board of Directors 
of Methodist Hospital and their terms of office or tenure 

for the following periods: 

(a) as of the time these Interrogatories are answered; 

(hb) as’ of January'l, 1976; 

(Cc): as of January 1,:1975; 

(3) as of January 1, 1974; 

(e) as of January 1, 197); 

(£) as oF January l, 1970; and « 

{g) as: of January 1, 1965. » 

Answer: 

Attached as Exhibits 1ll~a, 11-b 1ll-c, 11-4, 1ll-e, 1ll~- 
of and 11-g%s a list of the Board of Direcors in the 
respective years requested stating their name, residence, . 
occupation, race and sex. In addition, a check mark 
has been placed to the left of the name of the members 
who served on the Executive Committee of the Hospital, 
and this is in answer to Interrogatory No. 94. 

No record is kept as to the national origin of the 
members of the Board of Directors. The meaning of 

. the term national origin:is not clear to the defendant 
Methodist Hospital, and the defendant does not know 

what information the plaintiffs want. 

-10~- 

  

 



  

12. Describe briefly, but completely, the process 
of recruitment, selection, appointment and/or selection 
to the Board of Directors of Methodist Hospital. 

Answer: 

Since November 4, 1966, the Articles of Incorporation 
have provided as follows: 

Beginning in 1967, as vacancies occur on such 
Board through the expiration of the respective 
terms of members who are now serving on such Board, 
the Board of Directors of this corporation shall 
be named and designated in accordance with the 

following provisions: 

1) Not less than 21 members of the Board of 

Directors shall be members in good standing 
of a Methodist Church in the area of the 
Northwest Indiana Conference or a minister 
affiliated with a church in this conference 
area. 

2) Not less than three members of the Board 
of Directors shall be negroes. 

3) The Bishop of the Indiana Area of the Methodist 
Church, the District Superintendent of the 
Calumet District of the Northwest Indiana 
Conference of the Methodist Church, and the 
president of the Women's Auxiliary of the 
Methodist Hospital of Gary, Inc. shall be 

each ex officio members of the Board of Directors 
of this corporation. 

4) The Northwest Indiana Conference of the Methodist 
Church shall each year, at the annual conference, 

elect three members to the Board of Directors 
of this corporation, with the further proviso, 
however, that at least one of the directors 
so chosen shall be a layman who shall be a 
resident of the Calumet District of the Northwest 
Indiana Conference of the Methodist Church. 

Prior to the meeting of the Board of Directors 
of this corporation in April 1967, and in each 
year therafter, the President shall appoint a 
nominating committee consisting of five members 

of the Board of Directors. 

At the April meeting each year of the Board of 
Directors, the nominating committee shall place 
in nomination nominees for the officers of the 
Board of Directors and for membership on the executive 

committee. 

Such nominating committee shall likewise nominate 
each vear, beginning in 1967, eight persons for 
membership on the Board of Directors to serve 
for a term of three years succeeding the members 
whose terms expire in the year of such election. 

1 

    

 



§ é 8 . 

  

At the annual meeting of the corporation in July 
of each year the Board of Directors shall consider 
the nominations of the nominating committee for 
the officers of the Board for membership on the 
executive committee and for the 8 members on the 
Board of Directors. At such meeting, additional 
nominations for such offices may be received and 
considered. Such meeting shall then proceed to 
elect officers of the board and members of the 
executive committee, all of whom shall serve until 
the next annual meeting. The board shall also 
elect eight persons to membership on the Board 
of Directors, said persons to serve for a period 
of three years. The persons so elected shall 
take office immediately upon being elected. The 
terms of the persons elected for membership on 
the Board of Directors by the Northwest Indiana 
Conference shall likewise begin at the July meeting 
Of each year of the Board of Directors. In case 
of a vacancy on the Board of Directors, the Board 

of Directors shall fill such vacancy and the person 
elected to fill such vacancy shall serve for the 
unexpired term of the member to whose office he 
was elected. 

This is the procedure that has been followed. 

13. State whether Methodist Hospital has now or has 
ever had any policy or program to prefer or encourage minority 
persons for membership of a position on the Board of Directors 
of Methodist Hospital. 

Answer: 

The Articles of Incorporation as amended in November 
of 1967 provide as follows: 

"2) Not less than three members of the Board 
of Directors shall be Negroes." 

See answer to Interrogatory No. 11 for racial 
make-up of the Board of Directors in various years. 

The Hospital Board has sought representatives from 

all walks of life and background for Board representation. 

See also answer to Interrogatory No. 18. 

14. With reference to the organizational structure 
of Gary Methodist Hospital set forth in the answers to Inter- 
rogatory 7 identify the positions and levels of employment 
in each division, including all medical, nursing and other 
positions. 

-12- 

  

 



  

Answer: (Interrogatory No. 14) 

Generally, see answer to Interrogatory 5... The Hospital 
Personnel Manual provides as follows: 

"Tenure 1s the length of creditable, continuous 
full time employment at the hospital. It is used in 
determining your eligibility for benefits and service. 

"Your tenure will date from your original date of full 
time employment. However, tenure will be adjusted 
to compensate for an approved leave of absence. Considera- 
tion will be given to a full time employee (with at 
least one year tenure who transfers, temporarily, to 

part time status and later returns to full time employment. 
This person will have his original tenure date adjusted 
in the same manner as a leave of absence. Therefore, 
he will retain credit for his original period of employ- 
ment. If you terminate and are re-hired, full time, 

your tenure will start on the date of last re-employment. 
Tenure cannot be carried from one period of employment 
to another." 

This provision applies to all hospital employees. 

15. State. by race, national origin and sex (i.e., 
white males, white females, black males, black females, 
etc.,) the number of employees in each position and level 
by division at Gary Methodist Hospital as identified in 
the answer to Interrogatory 14: 

(a) As of the time these Interrogatories are answered; 
(bY. As of January '1l,.1976; 

{C) As OF January 1’ 1975; 

{d) As of January 1, 1974; 
(e¢) «- As of January 1, 1973; 

{F) "As Of January 1, 1972; 
{(g) As of January 1, 1971; 

(h) As of January 1l, 1970; and 

(i) ‘As of January 11,1965. 

Answer: 

No records kept by the Hospital state the number of 
black females or black males, or white females or white 
males; but the Hospital has Kept a record of the number 
of minorities employed and the number of males and 
females. Said records are not kept by position and 
level. They are as follows on the following dates: 

-13~ 

  

 



  

Answer to Interrogatory 15 (continuing): 
  

    

    

Sex Race® 

Date M F C N go net. 

8/12/77 154 842 322 595 33 37 9 

12/31/26 159 874 355 601 34 42 1 

1/1/76 181: 1082 579 619 35 | 3 37 

1/1/75 150 918 462 569 23 0 14 

1/1/74 140 876 488 490 21 2 14 

X/1/73 155 904 532 475 25 14 13 

Y/1/32 176 929 590 475 21 9 10 

X/x/71 No record—————=———— mmm 

X/1/710 JO record-————————m mmm 

1/1/65 NO record-—-————————m meme me 

*C - Caucasian; N - Negro; S - Spanish; 
OR - Oriental; O - Other 

The Hospital, prior to 1972, did not maintain such 
records. A racial and sexual breakdown as to each 
position may only be accomplished by a survey of personnel 

records of all existing employees. 

With regard to RN's, LPN's and aides, refer to breakdown 
and answer to Interrogatories Nos. 43 and 44. The 
above figures include all personnel on the dates stated. 

16. With reference to the organizational structure 
of Broadway Methodist Hospital set forth in the answers 
to Interrogatory 8 identify the positions and levels of 
employment in each division, including all medical, nursing 

and other positions. 

Answer: 

See answers to Interrogatories 1 and 2. 

There is no separate organizational structure excepting 
those listed. 

The positions and levels of employment have been previously 
stated. See also answer to Interrogatory 14. 

  

 



  

17. State by race, national origin and sex the number 
of employees in each position and level by division at Broadway 
Methodist Hospital as identified in the answers to Interrogatory 
15; 

(a) as of the time these Interrogatories are answered; 
and 

(hb) “as of January 1, 1976. 

Answer: 

No records kept by the Hospital state the number of 
black females, black males, white females, white males; 

but the Hospital has maintained a record of the number 
of minorities and the number of males and females in 
its employ. Said records are not kept by position 
and level. As to the Broadway facility, the records 
on the dates requested are as set forth below: 

  

      

Sex Race” 

Date Me F C N S OR 0 

8/12/77 63 451 412 87 10 4 1 

12/31/76 
1/3/77 62 407 378 79 10 2 - 

7/14/76 72 383 365 77 11 2 - 

1/1/76 No record; Hospital had been open 3 days. 

*C —- Caucasian; N - Negro; S - Spanish; 

OR - Oriental; O - Other. 

See also Exhibits 43 and 44. 

  

 



18. State whether Methodist Hospital has now or has 
ever had any program to prefer or encourage minority persons 
as employees for the purpose of increasing the number of 
minority group cmployees at either Gary Methodist Hospital, 
Broadway Methodist Hospital or both hospitals. 

  

Answer: 

The Hospital has had a long-standing policy to seek out 
and hire all qualified personnel. An emphasis has been 
placed on the recruitment and employment of minority em- 
ployees, especially in skilled and medical positions. 

The Hospital's Division of Education and Staff Services 
has participated and is participating in various quasi- 
governmental and community oriented programs to encourage 
and train as well as employ inner-city and minority residents. 
These programs include: Neighborhood Youth Corporation 
(since prior to 1964) in which 19 students took part this 
last summer and 4 were hired part time; Urban League of 
Gary, Inc. (since prior to 1967) in which one trainee 
was employed in 1977 (the Hospital still participates 
in this program despite the dearth of referrals from the 
Urban League); Work Incentive Program (since prior to 
1972) currently 19 trainees are enrolled and four former 

graduates are employed; C.E.T.A - the Hospital has worked 
with C.E.T.A., and some current employees were recruited 
through this program; the Gary Manpower Administration. 

As noted above, Gary Methodist Hospital has actively recruited 
qualified minority applicants for all positions. The 
Hospital's effort to recruit minority individuals for 
its medical staff has met with some success, as is evidenced 
by answers to other interrogatories herein (see, e.qg., 
Exhibit #45). The Hospital would note, however, that 
due to the deteriorating economic and sociologic conditions 
of the area which it serves, it has great difficulty re- 
cruiting qualified personnel of any race. The Hospital's 
recent efforts have been geared toward attracting qualified 

personnel irregardless of race, sex or national origin. 

The Hospital would also note that it has often expressed 

both by statement and operation its resolve to fully comply 
and implement Title VI of the Civil Rights Act of 19564. 
The Hospital has co-operated with the Department of Health, 
Education and Welfare in formulating all plans and programs. 

19. If the answer to Interrogatory 18 is affirmative, 

describe in full detail the duration, scope and nature of 

each such program and its result. 

Answer: 

See Answer to Interrogatory 18. 

20... If the answer to Interrogatory 18 is negative, 

state the reason why no such program has been undertaken. 

Answer: 

See Answer to Interrogatory 18. 

By 

  

 



  

21. State whether any agency, commission, organization, 
official, or other party (including the defendants) has 
made any investigation, evaluation, assessments, recommendation 

or other report concerning employment opportunities, conditions 
of employment, resolution of charges of discrimination, 
affirmative action programs, upward mobility programs, community 
attitudes, or other subjects related to employment of minority 
persons at Gary Methodist Hospital and/or Broadway Methodist 
Hospital. 

Answer: 

There have been no such investigations, assessments, 
etc., concerning employment at Methodist Hospital 
of Gary, Inc., excepting specific complaints made by 
former or present employees of the HOSpital filed with 
the Gary Human Relations Commission. 

22. For each investigation, evaluation, assessment, 

recommendation in Interrogatory 21 produce it or state: 

(a) the date or dates covered in each study or report; 

(b) the parties or agencies who prepared each study 
or report, and the date(s) of preparation; 

(c) a brief summary of each study or report; and 

"(d) whether any action was taken regarding the results 

of such study or report; and, if so, describe 
such action in full detail. 

Answer; 

Not applicable. 

23. Describe briefly, but completely, the criteria, 
or qualifications which individuals must meet in order to 
be considered for hiring to each position and level at Gary 

Methodist Hospital and Broadway Methodist Hospital and state 
whether, why and how such criteria is different for each 
hospital, or have changed since 1970. Identify or produce 
any studies, evaluations, assessments, investigations, or 
other reports which analyze the validity of such criteria 
or qualifications. 

Answer: 

The Hospital requires employees to be age 17 or older. 
Generally speaking an applicant must be able to read 
and write, but there are certain exceptions to this 
requirement; otherwise, job descriptions set the criteria. 
There is no difference in this respect between Gary 
and Broadway. See copies of Job descriptions attached 
as Exhibit 23. The procedure for filling positions of employment 

answered at Interrogatory 28. 

“YF = 

i 

  

 



  

24. Describe briefly, but completely, the process 

of application and acceptance to a position at Gary Methodist 
Hospital and Broadway Methodist Hospital up to and including 
the final acceptance and rejection for hiring, and state 

whether, why and how the process is different for each hospital. 

Answer: 

See attached chart entitled Application for Employment. 
There is no difference between the hospital facilities 
regarding said process. 

25. State whether tYecords are maintained of the race, 
national origin and sex of all applicants for hiring: 

(a) If such records are maintained, state by race, 

national origin and sex for each of the following 
periods the number of applicants for hiring for 
each position; identify the particular hospital, 
if any, for which the individuals applied for 
the following periods: 

(i) January 1, 1977 to the time these Interrogatories 

are answered; 

(11) : January 1, 19756 to December 31, 1976; 

(ili) ‘January 1, 1975 to December 21,.1975; 

(lv): January ll, 1974 to:December 31, 1974: 

(v) ‘January 1, 1973 to December 31, 1973; 

(vi) January 1, 1972 to December 31, 1972; 

(vii) ‘January 1, 1971 to December 31, 1971; 

{viii) January 1,.1970 to December 31, 1970; 
and 

{ix) ' January 1, 1965 to December 31, 1965. 

(b) If no such records are maintained, state whether 
the number, race, national origin and sex of ap- 
plicants can be tabulated, and, if so, provide 
the information requested in Interrogatory 25 (a). 
If your answer is in the negative, state the reason 
for such answer; identify all documents which 

are available pertaining to the race, national 

origin and sex of these applicants. 

Answer: 

Applications and applicant logs have been maintained 
and retained for the latter half of 1975 and the years 
1976 and 1977. Records of prior years have not been 
retained. As the application forms have no area for 
indication of race or national origin, only the applicant 
logs can be consulted to determine race. These logs 
are not complete and give only a partial synopsis of 
applicant race. A tabulation of the information contained 

in the logs is set out in Exhibit No. 23. 

  

 



  

26. State by race, national origin and sex the number 
of employees in each unit, division, position and level 

who applied for employment at Gary Methodist Hospital and 

who were hired for employment at Broadway Methodist Hospital. 

Answer: 

For those individuals who stated a preference for work at 

a specific site in their application for employment with 

Methodist Hospital, the following individuals stated a preference 

for the Broadway site but were hired for the Gary site: 

  

Division/Department Number Race Sex 
  

  

Finance: 

Accounting One White Female 

Credit Two : White Females 

Medical Records One White Female 

Education & Clinical: 

Physical Therapy One Black Male 

Radiology Three White Females 

Laboratory Three White Females 

EKG One White Male 

Respiratory Therapy One White Female 

Community Services: 

Communication Two White Females 

Housekeeping One White Female 

Health Education One White Female 

Emergency Room One White Female 

General Services: 

Dietary Four Black Females 

One Black Male 

Patient Care: 

Registered Nurses Three White Females 

Two Black Females 

One Oriental Female 

Lic.Practical Nurses Five White Females 

Nurses Aides Seven Black Females 

27. State by race, national origin and sex the number 

of employees in each unit, division, position and level 

who applied for employment at Broadway Methodist Hospital 

and who were hired for employment at Gary Methodist Hospital. 

~18~ 

  

 



  

Answer: {Interrogatory No. 27) 

For those individuals who stated a preference for work at 
a specific site in their application for employment with 
Methodist Hospital, the following individuals stated a 

preference for the Gary site but were hired for the Broadway 

  
  

  

site: 

Division/Department Number Race Sex 

Finance: 
Personnel One White Female 

General Services: 
Plant Operations One White Male 
Dietary One Black Female 

Patient Care: 
Registered Nurses Two - White Females 
Nurses Aides Two White Females 

28. State whether there is any process of application 
and acceptance for transfer from Gary Methodist Hospital 
to Broadway Methodist Hospital and from Broadway Methodist 
Hospital to Gary Methodist Hospital, and, 1f the answer : 
is affirmative, describe the process briefly, but completely. 

Answer: 

Yes. 

For other than management level positions and entry 
level positions, notice of a job opening is posted 
for 3 consecutive days, which may include one week- 

end day. The notice includes a brief job description, 

job requirements, rate of pay and date by which ap- 

plications must be submitted. Interested employees 

will be given an application to be completed with 
current information; anyone within the same department 
qualified to fill the position will be considered 

first. 

Applicants will then be interviewed accordingly, and 

when people of equal qualifications within the Hospital 

apply, seniority will be the deciding factor. 

Notices are posted on the Bulletin Board in the open 

corridor beside the Personnel Department Offices. 
On removal of the Notice, other sources will then be 

explored for filling the position. 

20. State whether black or other minority persons 

are given any preference, consideration, or special treatment 

in hiring, promotions and transfers at Gary Methodist Hospital 

and/or Broadway Methodist Hospital. 

Answer: See answer to Interrogatory 18. 

~~ 

  

 



  

30. escribe briefly, but completely, whether and 
how the number or percentage of any employees holding positions 
identified in the answers to Interrogatories 14 and 16 are 
restricted or limited. Identify of produce any studies, 
evaluations, assessments, investigations or other reports 
analyzing the validity of such restriction or limitation. 

Answer: 

No restrictions or limitations on race, creed, age, 
sex, religion or any other criteria exist. There 1is 

no quota system. 

Retirement age is 65, unless the Administrator authorizes 
the continued further employment, but not beyond age 
72. 

The balance of the question is not applicable. 

31. Identify or produce any documents which relate 
to any restriction or limitation identified in Interrogatory 
30, including persons denied employment, promotion or transfer 
on such basis by position and level, name, race, national 

origin, sex and date. 

Answer: 

See Exhibit 31. 

32. State whether any facilities operated by Methodist 
Hospital are now used or have ever been used on a racially 
segregated basis. If the answer is in the affirmative, 

identify and give the reason for such usage. 

Answer: 

At the present time no facilities operated by the defendant 
Methodist Hospital of Gary are used or provided on 

a racially segregated basis. 

Prior to 1963, patient rooms were racially segregated 
in certain departments of the Hospital. During the 
early 1960's and prior thereto, many patients stated 
their desire to be segregated. In addition, the avoidance 
of any tension or anxiety resulting from integration 
of rooms was thought to be in the best interests of 

the ill patient. 

33. Describe briefly, but completely, the procedure 
used in filling permanent job vacancies. State whether 

any preference is given to present employees or their relatives 
or to persons living within the vicinity of Gary Methodist 

Hospital and Broadway Methodist Hospital. 

0) 

  

Eo Ma TE I SEE 
ws Doi PB wn BE DE dN 

  

wo Epa aii! RE Sa RRA 8  



  

Answer: {(Interrogatory No. 33) 

Preference is given to present employees for other 
than entry-level positions. For other than administrative 
staff positions, management level positions, and entry- 
level positions, notice of a job opening is posted 
for 3 consecutive days which may include one weekend 
day. The notice includes a brief job description, 
job requirements, rate of pay and date by which ap- 
plications must be submitted. Interested employees 
will be given an application to be completed. Anyone 
within the same department qualified to fill the posi- 
tion will be considered first. 

Applicants will then be interviewed and when people 
of equal qualifications within the hospital apply, 
senority will be the deciding factor. 

On removal of the Notice of Job Opening without an 
application having been received, the Hospital will 
explore other sources to fill the position. Notices 
are posted on the Bulletin Board in the corridor at 
the Personnel Office which happens to be approximately 
25 feet from the cafeteria for all employees, visitors, 
and guests of the Hospital. 

Preference is not given to relatives of employees or 
persons living within the vicinity of one hospital 
or the other. 

34. Describe separately, briefly, but completely the 
function, purpose and significance of voluntary, temporary 
and part-time positions at Gary Methodist Hospital and Broadway 
Methodist Hospital; and whether, how and why the function, 
purpose and significance has changed at Gary Methodist Hospital 
since 1975. 

Answer: 

There has been no change in the function, purpose or 
significance of voluntary, temporary or part-time posi- 
tions at either hospital since 1975. 

The Personnel Manual as to part-time and temporary 
employees provides as follows: 

"PART-TIME EMPLOYEES 

"A part-time employee is normally scheduled to 
work not more than thirty-two hours per week. 
Part-time employees are included in the Social 

Security program, the use of Employee.Health Service 
and are eligible for discounts in the Hospital 
Pharmacy." 

-_— 

  

 



  

Answer to lnterrogatory 34 (continuing): 
  

"TEMPORARY EMPLOYEES 

"A temporary employee is employed for a specified 
length of time, not to exceed six months. 

"The employee may work forty hours per week. 
He 1s paid at the beginning wage rate set for 

the position filled. If transferred to a permanent 
full-time position, the effective date of transfer 
becomes the tenure date. 

"Temporary employees are included in the Social 
Security program and Employee Health Service." 

The Hospital utilizes part-time or temporary employees 
only when the need justifies such employment or only 
when part-time or temporary employees are the only 
employees available. 

VOLUNTEER EMPLOYEES —-- See Exhibit 34 and the answer 
to Interrogatory No. 36. 

35. Describe briefly, but completely, by each unit, 
position and level, the process of application and acceptance 
for voluntary, temporary and part-time positions at Gary 
Methodist Hospital and Broadway Methodist Hospital; whether 
there is one process for both hospitals, and whether, how 
and why the process has changed since 1975. 

Answer: 

See answer to Interrogatory 33, as the procedure for 
filling part-time and temporary positions is the same 
procedure in filling permanent positions. 

The volunteer organizations, being the Women's Auxiliary, 
Junior Guild and Senior Guild handle all indications 
of willingness to do volunteer work. From time to 
time, they have drives to sign up volunteers. 

See also Exhibit 35. 

Le A 

  

 



  

36. State whether records are maintained of the race, national origin and sex of all persons who have sought appointment to voluntary, temporary and part-time positions at Gary | Methodist Hospital: 

(a) if such records are maintained, state by race, 
national origin and sex for each of the following 
periods the numbers of persons who have sought 
such appointments, identifying the position sought; 
the number who were qualified or eligible for 
such appointment; the basis of selection; officials 
Or supervisors in charge of selection; and the 
number accepted and rejected: 

(1) January 1, 1977 to the time these Interrogatories 
are answered; 

(ii) January 1, 1976 to December 31, 1975; 
(1ii) January 1, 1975 to December 31, 1975; 
(iv) January 1, 1974 to December 31,1974; 
(v) January 1973 to December 31, 1973; 

(vi) January 1872 to December 31, 1072; 
(vii) January 1971 to December 31, 1971; 

(viii)--January 1970 to December 31, 1970; 
(ix) January 1, 1965 to December 31, 1965. 

~ 
~ 

-
 

b
p
 

~~
 

(b) If no records are maintained, state whether the 
race, national origin and sex of those who have 
sought such appointment can be tabulated, and, 
if so, provide the information requested in Inter- 
rogatory 36(a). If your answer is in the negative, 
identify all documents which are avallable pertaining 
to the race, national origin and sex of those 
who have sought such appointment; the total number 
who have sought such appointment, the number who 
qualified or were eligible for such appointment, 
the basis for selection, officials Or supervisors 
in charge of selection, and the number accepted 
and rejected for each of the periods set forth 
in Interrogatory 36 (a). 

Answer: 

Records are maintained for the years 1976 and 19877 
concerning the race, sex and number of applicants qualified 
and hired for the following positions on a part-time 
basis. Partial records are maintained for the latter 
one-half of the year 1975 for the Gary site only. 
No records are kept of the race of volunteer applicants. 
The records concerning volunteer applicants consist 
of the applications themselves which have been retained 
for the years 1971 to present. The records for parct- 
time and temporary applicants consist of the applications 
themselves (1976 and 1977) and applicant logs (July, 
1975 to present). Records are kept of temporary applicants 
only for summer positions. 

-24~ 

  

 



  

Answer No. 36 (continuing): 
  

Each applicant was qualified for the position noted. 

If an individual was clearly not qualified for the 
position for which he or she applied, the application 
was modified with the applicant's approval. If the 
applicant was clearly not qualified and refused modification, 
the application was not retained. 

The applicants were selected on the basis of their 
particular qualifications, the special attributes and 
conditions of the position vacant, the applicant's 
availability at the time the position became vacant 
and the interview conducted by the supervisor or department 
head making the final employment decision. 

Volunteer applicants are all accepted and assigned 
as the need for their services arises. If a volunteer 
applicant is clearly not suited for volunteer work 
with the Hospital (would, in the judgment of the volunteer 
supervisor, have a detrimental effect on the patient 
population), that volunteer will not be assigned duty. 
All volunteers undergo a six-month probationary period. 

A special effort has been made by the volunteer supervisor 
to utilize physically and/or mentally handicapped individuals 
in volunteer work. Often this volunteer work is part 
of a therapy program under the supervision of the individual's 
physician. 

A list of the various supervisors and department heads 
who make the applicant selection decision can be found 

in the materials in response to Interrogatory 5. 

PART TIME - GARY SITE 

  

Division - Job Number Race Sex 

1975 

General Services: 
Diet One White Male 

One White Female 

One Black Female 

NONE HIRED 

Porter One White Male 
NONE HIRED 

Education and Clinic: 
Lab Technician One White Male 

NONE HIRED 

F-M.T. One White Male 

NONE HIRED 

Patient Services: 
Registered Nurse One White Female 

HIRED 

Lic. Pract. Nurse Four White Females 
ONE HIRED 

Nurses Aides Four White Females 
One Black Female 

HIRED ONE WHITE 

Finance: 

Clerical Six White Females 
TwO Black Females 

NONE HIRED 

-35 

  

 



  

Answer No. 36 (continuing): 
  

PART TIME - GARY SITE 

  

    

Division - Job Number Race Sex 

1976 

General Services: : 

Diet Three Black Females 
Two White Females 
NONE HIRED 

Housekeeping Three Black Females 
One Black Male 

NONE HIRED 
Porter TwO Black Males 

One White Male 

NONE HIRED 

Summer (Temporary) One Black Female 

One White Female 
One White Male 
NONE HIRED 

Education and Clinical: 

E.M.T. Four White Males 

One White Female 

HIRED ONE WHITE MALE 

Lab Technician One White Female 

One White Male 
One Black « Male 
HIRED: ONE BLACK MALE 

Radiology One Black Male 

NONE HIRED 

Patient Services: 

Registered Nurse Six White Females 

NONE HIRED 

Lic. Pract. Nurse Two White Females 

Two Black Females 

HIRED ONE BLACK FEMALE 

Nurses Aides Two White Males 

Five White Females 
Three Black Females 

One Oriental Male 
One Hispanic Female 

NONE HIRED 

Finance: 

Clerk Eight White Female 

HIRED ONE 

wg 

  

 



  

Answer No. 36 (continuing): 
  

PART TIME - GARY SITE 

  

  

Division - Job Number Race Sex 

1977 

General Services: 
Housekeeping One Black Female 

One White Female 

One White Male 

: NONE HIRED 

Porters Eight Black Males 
HIRED ONE 

Summer (Temp.) Two White Females 
Four Black Females 

One Black Male 

NONE HIRED 

Diet Two Black Females 
NONE HIRED 

Education and Clinic: 
EEG Technician One Black Female 

NONE HIRED 

EKG Technician One White Female 
HIRED 

Lab Technician One Black Female 
NONE HIRED 

Patient Services: 

Registered Nurse Two White Females 
NONE HIRED : 

Lic. Pract. Nurse Two Black Females 
One White Female 
HIRED ONE BLACK FEMALE 

Nurses Aides One Black Male 
Four Black Females 

Three White Females 

NONE HIRED 

-27- 

  

 



  

Answer No. 36 (continuing): 
  

PART TIME - BROADWAY SITE 

  

Division - Job 

1976 

General Services: 
Housekeeping 

Security 

Diet 

Summer (Temp.) 

Education and Clinic: 

Lab. Technicians 

EKG Technician 

EMT Technician 

Patient Services: 
Registered Nurse 

Lic. Pract. Nurse 

Nurses Aides 

Orderly 

Finance: 
Pharmacy 

Clerical 

  

  

Number Race Sex 

Two White Males 

Two White Females 

Two Black Females 

NONE HIRED 

One Black Female 

NONE HIRED 

Six White Females 
Three Black Females 

NONE HIRED 

Four White Males 

One Black Male 
Two Black Females 

Four White Females 

NONE HIRED 

Three White Females 
One ‘Black Female 

NCNE HIRED 

One White Female 
NONE HIRED 

One White Male 

NONE HIRED 

Seven White Females 
TWO HIRED 

TWO White Females 

NONE HIRED 

Sixteen White Females 
TwO Black Females 

HIRED: TWO WHITE FEMALES 

ONE BLACK FEMALE 

TWO White Males 

One Black . Male 

One Hispanic Male 

NONE HIRED 

One White Female 

NONE HIRED 

Twenty-Four White Females 
One Black Female 

NONE HIRED 

<3 

  

 



  

Answer No. 36 (continuing): 
  

PART TIME - BROADWAY SITE 

Division - Job 
  

1977 

General Services: 
Housekeeping 

Porter 

Summer (Temp.) 

Diet 

Bducation and Clinic: 

Respiratory Therapist 

Lab Technician 

Phlebotomist 

Patient Services: 
RegisteredNurse 

Lic. Pract. Nurse 

Nurses Aides 

Orderly 

Finance: 

Pharmacist Asst. 

Number Race 

TO White 

Seven White 

Six Black 
NONE HIRED 

One Black 

NONE HIRED 

One White 

Ten White 
One Black 

NONE HIRED 

Two White 
Two Black 

HIRED ONE WHITE FEMALE 

One White 
NONE HIRED 

One White 
NONE HIRED 

One White 

NONE HIRED 

Ten White 
ONE HIRED 

Two White 

ONE HIRED 

Fourteen White 

Two Black 

NONE HIRED 

Two White 
NONE HIRED 

One White 
NONE HIRED 

Sex 

Females 

Males 

Males 

Male 

Male 

Females 

Female 

Females 

Females 

Female 

Female 

Female 

Females 

Females 

Females 

Females 

Males 

Male 

  

 



  

Answer No. 36 (continuing): 
  

VOLUNTEERS: 

For the following years, the volunteers noted applied for 
and did some work at the Gary site: 

1971 1972 1973 1974 1975 

Pink Ladies (F) 61 37 46 44 59 

Red Coats (M) 7 2 3 5 2 

For the following years, the new volunteers are broken down 
by those doing work at each site: 

  

1976 Gary Broadway 

Pink Ladies (F) 0l 28 

Red Coats (M) 8 l 

1977 

Pink Ladies (F) 52 17 

Red Coats (M) 0 3 

Active Volunteers: 
Pink Ladies (F) 155 153 
Red Coats (M) 3 12 

Candy Stripers (F) 25 13 
(Females under 18 years old) 

-30- 

    

 



  

38. Describe briefly, but completely, the geographic 
area from which Methodist HOspital draws its employees: 

(a) for each position and level at Gary Methodist 
Hospital; 

(b) for each position and level at Broadway Methodist 
Hospital. 

Answer; 

The majority of employees live in Lake County and in the 
Gary-Merrillville area. Smaller percentages of employees 
live outside the Gary-Merrillville area, and an even 
smaller percentage live outside of Lake County. 

39. Describe separately for each hospital the process, 
criteria and standards of recruitment, application and selection 
of registered nurses, licensed practical nurses, graduate 
student nurses and nurses aides at Gary Methodist Hospital 
and Broadway Methodist Hospital, including whether, why 
and how the process, criteria and standards differ for the 
two hospitals and whether, why and how the process, criteria 
and standards have changed since 1975. 

Answer: 

There is no separate process, criteria or standard 

.0f recruitment, application or selection of nurses 
at Gary or Broadway, and the criteria and standards 
do not differ. The process, criteria and standards 
have not changed since 1975. 

Nurses aides and ward secretaries are selected from 

applicants that meet the standard employee requirements 
of the Hospital. 

Experienced licensed practical nurses are selected’ 
from applicants having satisfactory references. 

New graduates are employed if they are eligible to 
take a State Board exam for licensing. 

Experienced registered nurses are selected from applicants 
that have satisfactory references. Graduate nurses 
are employed if they are eligible to take a State Board 
exam for licensing. 

Recruiting is done at local universities and by advertisement 
on radio and in newspapers. Newspaper ads in areas 
where there were known unemployed nurses has not been 
successful. The Hospital recently offered a finder's 
fee or bonus for anyone bringing the Hospital an R.N. 
who would work at Gary Methodist Hospital for 6 months. 
No new R.N.'s came as a result of this program. 

-3]1- 

  

 



  

40. Describe briefly, but completely, the conditions, 

perquisities and/or requirements of employment for registered 

nurses and nurses aides at Gary Methodist Hospital, including 

but not limited to the availability of housing, transportation 

and meals. State the date on which each such condition, 

perquisite and/or requirement was instituted, whether, how 

and why they have changed and the number of persons at each 

level, by race, national origin and sex who are subject 

to, take advantage of or utilize such conditions and facilities 

from: 

(a) January, 1977 to the time these Interrogatories 

are answered; 

(b) January 1, 1976 to December 31, 1976; 

{Cc} January l,:1975 to December 31, 1975; 

(d) January 1, 1974 to Baoan 31, 1974; 

{(e) January: 1, 1973 to December 31, 1973; 

(£) January 1, 1972 to December 31, 1972; 

(g) January 1, 1971 to December 31, 1971; 

(h} January 1, 1970 to December 31, 1970; 

(i) January 1, 1965 to December 31, 1965. 

Answer: 

See answer to Interrogatory 39. 

The Methodist Hospital of Gary, Inc. closed its School 

of Nursing in 1967 and since that date has had available 

35 rooms in the nursing school dormitory. Nurses recruited 

from the Phillipines presently reside in this building 

adjacent to the Hospital. Meals are available in the 

Hospital cafeteria. 

There is private housing and public transportation 

available in Gary. In 1975 the Hospital hired 40 registered 

nurses from the Phillipines, and 29 of such nurses 

reside in the nursing home, and some of them take advantage 

of the Hospital cafeteria. The Hospital provides no 

housing or meals other than as stated 

above. Transportation is being provided on an experimental 

basis between the two hospitals at the present time. 

The rooms available in the old nursing home building 

are: Females - 27 double rooms, 2 single rooms; 

Males - 2 double rooms, 4 single rooms. 

~32- 

  

 



  

41. Describe briefly, but completely, the conditions, 
perquisites and/or requirements of employment for registered 
nurses, licensed practical nurses, graduate student nurses, 
and nurses aides at Broadway Methodist Hospital, including 
but not limited to the availability of housing, transporta- 
tion and meals. State the date on which each such condition, 
perquisite and/or requrement of employment was instituted; 
whether, how and why they differ from those at Gary Methodist 
Hospital; the number of persons at each level, by race, 
national origin and sex who are subject to, take advantage 
of or utilize such conditions and facilities since December, 
1975. 

Answer: 

See answer to Interrogatory 39. No housing or meals 
(other than use of the Hospital cafeteria) are provided 
nurses or aides at Broadway. Transportation is being 
provided on an expiremental basis between the two hos- 
pitals at the present time. 

42. Describe separately for each hospital, the process, 
criteria and standards for determining the number of employees 
on the nursing staff of Gary Methodist Hospital and Broadway 
Methodist Hospital, including the separate process, criteria 
and standards with respect to registered nurses, licensed 
practical nurses, graduate student nurses, nurses aides 
and non-medical and non-nursing staff. State whether, why 
and how the process, criteria and standards differ for the 
two hospitals, and whether, why and how the process, criteria 
and selection has changed since 1975. 

Answer: 

See answers to previous Interrogatories 39, 40 and 
41. No change since 1975. 

Within the confines of the criteria set forth below, 
assignment of hospital is based on personal preference 
and availability of position. 

Staffing patterns are established for each nursing 
unit at both hospitals using the same criteria for 
needs. This criteria is patient census and type of 
illness cared for in the unit. On the average these 
patterns are composed of 2/3 RN's and LPN's and 1/3 
aldes and ward secretaries for a patient employee ratio 
of 1 to 5-6 or 4.2~4.5 hours per patient day. 

The Hospital has been able to fill all RN and LPN positions 
at Broadway but not all vacancies at Gary. Nurses 
in both categories have refused employment when asked 
to work at Gary. 

-33- 

  

 



  

43. Describe briefly, but completely, the training 
and experience (i.e., student, foreigh-trained, what country, 
American-trained, licenses, etc.) of each registered nurse, 
practical nurse, aide, and other member of the nursing staff 
at Gary Methodist Hospital who was employed or worked from: 

(a) January 1, 1977 to the time these Interrogatories 
are answered: 

(b) January 1, 1976 to December 31, 1976; 
(cc) January 1, 1975 to December 31, 1975; 

(dA) January 1, 1974 to December 31, 1974; 

(e) January 1, 1973 to December 31, 1973; 
(£) January 1,.1972 to December 31, 1972; 

{g) ‘January 1l, 1971 to December 31, 19571; 

(h) January 1, 1970 to December 30, 1970; 
(1) January 1, 196 to December 31, 1965. 

2 7 / A 
“FL 

{ FOF ) 4 - 

Answer: 

\ . 

See Exhibit 43A, pages 1-16, stating school attended 
and years of experience of Registered Nurses at Gary 
Methodist. I.U.N.W. 1s Indiana University Northwest 
at Gary. The dates are found in the lefthand margin. 
A - American and F - foreign. 

See Exhibit 43B, pages 1-11, stating school attended 

and years of experience. A - Amercan and F - foreign 

with respect to training. Dates are in the left-hand 
margin. 

See Exhibit 43C, pages 1-18, stating training and ex— 
perience of aides and technicians. 

44. Describe briefly, but completely, the training and 
experience of each registered nurse, practical nurse, nurses 
aide, and each other member of the nursing staff at Broadway 
Methodist Hospital who was employed or worked from: 

(a) January 1, 1977 to the time these Interrogatories 
are answered, and 

(b) from January 1, 1976 to December 31, 1976. 

Answer; 

See Exhibits 44A4 pages 1-4, describing education and 
experience of Registered Nurses at Broadway. Dates 
are in the left-hand margin. A is for American training, 

and F for foreign training. 

See Exhibit 44B, pages 1-2, describing same for Licensed 

Practical Nurses at Broadway. 

See Exhibit 44C, pages 1-4, describing same for aides 

at Broadway. 

-34- 

  

 



  

45. Identify the number of physicians employed on 
the medical staff of Gary Methodist Hospital by name, address, 

specialty, national origin and sex, specifying whether each 

is a specialist, physician who has completed training, resident, 
intern, extern or consultant for the periods from: 

(2a) January 1, 1977 to the time these Interrogatories 
are answered; 

(b) January 1, 1976 to December 31, 1976; 

{c) "Januaryi+l, 1975 to December 31, 1975; 
(d) January 1, 1974 to December 31, 1974; 

{e) January 1, 1973 to December 31, 1973; 
(£) January 1, 1972 to December 31, 1972; 

{g) "January l, 1971 Lio December. 31, 1971; 

(h) January 1 

(i) January 1 

, 1970 to December 31, 1970; 

s+ 1965 to December 31, 1965. 

Answer: 

No physicians are employed on the medical staff at Gary 
Methodist Hospital. There is only one medical staff 
covering the two hospital locations, and no physicians 
are or have been employed by the Hospital except for 

a medical education position. 

See also Exhibit 45./ 

46. Identify the number of physicians employed on 

the medical staff of Broadway Methodist Hospital by name, 

address, specialty, race, national origin and sex, specifying 

whether each is a specialist, physician who has completed 

training, resident, intern, extern or consultant for the 

periods from: 

(a) January 1, 1977 to the time these Interrogatories 

are answered; 

{(b) January 1, 1976 to December 31, 1976. 

Answer; 

No physicians are employed on the medical staff at the 

Broadway location of Methodist Hospital of Gary, Inc. 
See also answer to Interrogatory 45 and Exhibit 45. 

  
  

 



  

47. Identify the number of physicians with staff privi-. 

leges at Gary Methodist Hospital by name, address, specialty, 

race, national origin and sex, specifying whether each is 

a specialist, physician who has completed training, resident, 

intern, extern or consultant for the periods from: 

(a) January 

(b) January 

(c) January 
(d) January 
(e) January 
(Ff) “January 

(g) January 

1976 to December 31, 1976; 
1975 to December 31, 1975; 
1974 to December 31, 1974; 
1973 to December 31, 1973; 
1972 to December 31, 1972; 

1971 to December 31, 19571; 

1970 to December 31, 1970. a
 

nl
 

nl 
al 

al 
a 

- 
- 

“~
 

~-
 

~-
 

~ 
- 

Answer: 

See Exhibit 45. 

48. Identify the number of physicians with staff privileges 

at Broadway Methodist Hospital by name, address, specialty, 

race, national origin and sex, specifying whether each is 

a specialist, physician who has completed training, resident, 

intern, extern or consultant for the following periods: 

(a) January 1, 1977 to the time these Interrogatories 

are answered; 

(b)} © January 1, 1976 to December 31, 1976. 

Answer: 

See Exhibit 45. 

49. Describe briefly, but completely, the training 

and experience of each specialist, physician who has completed 

training, resident, intern, medical aide, extern, consultant 

and other member of the medical staff at Gary Methodist 

Hospital, including place of educational training, date 

of graduation, years and type of experience, professional 

titles and board certification, if any, and specialty. 

Answer: 

See Exhibit 45. 

-36- 

  

 



) » . is 

  

50. Describe briefly, but completely, the training 
and experience of each specialist, physician who has completed 
training, resident, intern, medical aide, extern, consultant 
and other member of the medical staff at Broadway Methodist 
Hospital, including place of educational training, date 
of graduation, years and type of experience, professional 
titles and board certification, if any, and specialty. 

Answer: 

See Exhibit 45. 

51. State whether Gary Methodist Hospital and/or Broadway 
Methodist Hospital has or had any arrangement with a medical 
school under which the facility or students provide or have 
provided services at the hospital and/or the hospital provides 
services to the medical school. 

Answer: 

Yes. 

52. If the answer to Interrogatory 51 is affirmative, 

(a) describe briefly, but completely, the arrangement, 
specifying all aspects including, but not limited 
to the name and location of the school, the type 
of services, the extent of services, the period 

of time such arrangement has lasted or did last, 

which hospital or hospitals the arrangement covers, 
and whether any document describes, outlines, 
memorializes or governs such arrangement; 

(b) state separately by category and hospital, the 
number of physicians, externs and interns who 
are affiliated with the medical schools which 
have a current arrangement with the hospitals. 

Answer: 

(a) 

1) Agreement between I.U. Medical School, Medical 
Center of Gary and Methodist Hospital dated April 1, 

1976. Purpose - to provide facilities for instruction 
for clinical experience for students enrolled in Health 
Practioner Program. Essentially the Hospital agreed 
to furnish clinical experience in all available patient 
care areas and to provide classroom and conference 
space on or nearby the clinical setting and to allow 
students to observe or consult with personnel and medical 
staff from any of the patient care departments and 
to make the Hospital library available to such students. 

—-37- 

  

 



  

Answer No. 52 (continuing): 
  

Contract to be effective until cancelled by either 
of parties. Agreement doesn't specify which 
hospital. : 
This contract ‘applies to both Facilities, but, 
the program has generally utilized the Gary facility 
because of available classroom space, etc. ; 

2) Agreement between I.U. School of Medicine, Division 
of Allied Health Services and Methodist Hospital 

for clinical experience for Medical Records Tech- 
nicians. Methodist Hospital provides a supervised 
program of clinical experience for Medical Records 

Technology students. Contract doesn't specify 
hospital location. Contract now in effect. 'Generally 
the Gary facility is utilized, because the Medical 
Records Director is in Gary and the volume is 
higher in Gary. 

3) Methodist Hospital provides other educational 
affiliations with 1I.U. but not related to their Medical School 
or Nursing School which are not described in these 

answers. 

. 4) Agreement between Methodist Hospital of Gary and 

Division of Allied Health Sciences I.U. School 
of Medicine for a Field Work Experience Program in 
Respiratory Therapy, wherein the Hospital provides 
a supervised program of Field work experience. This 
program available at Broadway and at Gary. This 
affiliation is approved by AMA Council on Medical 
Education. Current agreement date is April, 1977. 
The students generally utilize the Broadway facility 

because of greater space at Broadway in this department. 

(b) 

These affiliations are between local doctors and the 

applicable Medical Centers and Schools. The Hospital 

is aware that between 14-20 members of its medical 

staff have an affiliation with a Medical School and 

from time to time perform some teaching function. 

Methodist Hospital has no externs or interns. 

: 53. If the answer to Interrogatory 51 is affirmative 

for one hospital only, state why arrangement were made for 

that one hospital only. 

Answer : 

See Answer to Interrogatory 52. 

hf 

  

 



  

54. State whether Gary Methodist Hospital and/or Broadway 
Methodist Hospital has or had any arrangement with a nursing 
school under which the facility and students provide or 
have provided services at the hospital and/or the hospital 
provides or has provided services to the medical school. 

Answer: 

Yes. 

55. If the answer to Interrogatory 54 is in the affirma- 
tive, describe briefly, but completely, all terms of the 
arrangement, including but not limited to the name and location 
of the school, the extent and nature of the services, the 
period of time such arrangement has lasted or did last, 

which hospital or hospitals the arrangement covers, and 
whether any document describes, outlines, memorializes or 

governs such arrangement. 

Answer: 

A) Hospital has contract dated 5/9/77 with I.U. Nursing 
School - in effect until revised or terminated - 
purpose to provide facilities for instruction 
for clinical experience for students enrolled 
in the Associate of Science Degree in Nursing. 
The clinical experience is to be and has been 
in Medical, Surgical, Maternity, Pediatric and 
Psychiatric nursing. Hospital provides classrooms 
and conference space near the clinical setting 
and allows observation by students and consultation 
in patient care departments and other departments. 
The hospital building is made available to students 
and faculty. Agreement doesn't specify which 

hospital. 

This agreement supersedes a prior agreement with 
1.U. School of Nursing dated 1/20/69. This affilia- 
tion is a long standing one going back a number 

of years. 

Methodist Hospital has also made available a loan 

program providing room and board for up to 10 
students per vear from 1.U. School of Nursing 
which loan has been forgiven if the student is em- 
ployed at Methodist Hospital for one year following 
graduation. This program has been in effect since 

1969. 

The Department of Health Services is available 
to the nursing students for immunization, office 
calls, chest x-ray, T.B. test, serology test, 
etc. The student is entitled to employee discounts 

in the Hospital pharmacy. 

-390— 

  

 



Answer to Interrogatory 55 (continuing): 

  

  

This agreement while not specifying any hospital 
location has been performed at Gary Methodist 
Hospital. 

B) Purdue University R.N. (Both B.S. and A.D. programs)- 
Agreement dated 9/16/70 between Purdue University 
and Methodist Hospital =-- clinical education to 
students of nursing in University Baccalaureate 
Degree Program -- Hospital to provide classrooms 
and conference space -- opportunity for student 
practice and observation -- use of library, orientation 
to hospital, acceptance of nursing students. 
Hospital also provides students routine health 
service and pharmacy at reduced rates. Agreement 
continued until October, 1976, when revised agreements 
were prepared. 

New agreement provided for clinical experience 
for Baccalaureate and Associate Degree Programs 
in Nursing. Agreement to continue to 1/1/78. 
Hospital provides space and co-ordination and 
University provides instruction and supervision. 
Separate but identical agreements proposed for 
Gary and Broadway at request of Purdue, i.e., 
State Nursing Board requirements. Both agreements approved 
by Indiana State Board of Nurses Registration 
and Nursing Education. 

C) Methodist Hospital has been affiliated with Purdue 
University in its Licensed Practical Nurse Program 
since May, 1970. The last agreement, dated 6/23/73, 
provides that the Hospital: 

1) Accept Practical Nurse students for a course 
of instruction and clinical experience in 
Medical Nursing; 

2) Provide a clinical instructor for classroom 
instruction and supervised clinical experience; 

3) Provide direct supervision by an RN in all 
patient units, where students are assigned for 
clinical experience; 

4) Allow students to observe and consult with 
personnel from Patient Care Departments; 

5) Make available classrooms, conference rooms 
and library; 

6) Provide health service. 

This was discontinued by Purdue in January, 1977. 
Methodist was the only hospital in the area which 
offered to continue the program. 

D) Methodist Hospital had an agreement with Valparaiso 
School of Nursing ~ commencing 5/19/72 for clinical 
experience of student nurses from Valparaiso University. 
The agreement doesn't specify which hospital shall 
be utilized, and the program applies to both hospitals. 
The Gary facility is the only Facility utilized 
by Valparaiso University, as the Gary facility 

contains the departments which such students utilize. 

E) Methodist Hospital has many other educational 
affiliations and agreements with educational 
institutions which are not medical schools or 
nursing schools, and such agreements are not covered 
here. 

Ti 

  

 



  

56. If the answer to Interrogatory 54 is affirmative 
for one hospital only, state why arrangements were made 
for that one hospital only. 

Answer : 

Not. applicable. 

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

(a) As of the time these Interrogatories are answered; 

{b) As of January 'Y¥, 1977; 

{c) As of January 1, 1976; i 
} «As of January 1,.1975; 

(e) As of January 1, 1974; 
Y= As Of January 1, 1973; 

{(g) As of January 1, 19790. 

Answer: 

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 Januvary'l,-1976. 

Answer: 

See Exhibit No. 58. 

-4] — 

  

 



  

59. If the entire or part of the physician staff of 
Methodist Hospital has joint staff privileges or employment 
on the staffs of Gary Methodist Hospital and Broadway Methodist 
Hospital, state whether records are maintained which indicate 

the time allocated by the medical staff as between the two 
hospitals: 

(a) 

(b) 

if such records are maintained, identify each 

physician by race, national origin and sex and 
state the number of patients admitted by each 
physician and patient days by payment and race; 
and the amount of days he or she has worked at 
Gary Methodist Hospital, on the one hand, and 
Broadway Methodist Hospital, for the following 
periods: 

{i) ‘January Xl, 1977 to March 30, 1977; 
(ii) January 1, 1976 to December 31,:1976, and 

(iii) January 1, 1976 to June 1}, 1976. 

if no such records are maintained, state whether 
the information requested in Interrogatory 59 (a) 

can be tabulated and, if so, provide it. If your 
answer is in the negative, state the reason for 
such answer; identify all documents which are 

available pertaining to the information requested 
in Interrogatory 59(a). 

Answer: 

a) 

b) 

Such records are not maintained. 

Such information cannot be tabulated as there are 

no records of same. 

—-f4 = 

  

 



  

60. If there are separate medical staffs at Gary Methodist 
Hospital and Broadway Methodist Hospital: 

(a) separately state the ratio of specialists, indicating 
specialties, physicians who have completed training, 
residents, externs and interns to patients at 
Gary Methodist Hospital: 

(1) as of the time these Interrogatories 
are answered; 

(11) as of January 1, 1976; 
(111) as of January 1, 1975; 
(iv) as of January 1, 1974; 
{v).:as Of January il, 1973; 

(vi) as of January 1, 1972; 
(vii) as of January 1, 1971; and 

(viii) as of January 1, 1970. 

{b) separately state the ratio of specialists, indicating 
specialties, physicians who have completed training, 
residents, externs and interns to patients at 
Broadway Methodist Hospital: 

(1) as of the time these Interrogatories 

are answered; 

(il) as of (January 1, 1977; 
{(1ii) as of January 1, 1976; and 

(iv) as of January 1, 1975. 

Answer: 

Not applicable. 

61. 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; 
(hb) ‘as of January X, 1977; 
{C) as of ‘January 1,:.1975; 
{d). as of January 1,:1975; 
(e) as of January 1, 1974; 
{E) as of January 1, 1973; 
{g) as of January -l, 1972; 

(h) as of January ‘1, 1971; and 
(1) as of January 1, 1970. 

Answer: 

See Exhibit 61. 

—~4 3= 

  

 



  

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

(a) a 

(b) a 

(c) 

s of the time these Interrogatories are answered; 
s Of January 1,:1977; and 
8s of January 1, 1976. 

Answer: 

See Exhibit 62. 

63. Identify all physicians who do not admit patients 
but perform services (e.g., anesthesiology) upon a referral, 
contractual or employment relationship with other physicians 
at Gary Methodist Hospital by name, race, national origin, 
sex and specialty. 

Answer: 

See answers to Interrogatories 47 - 50. 

64. Identify all physicians who do not admit patients 
but perform services (e.g., anesthesiology) upon a referral, 
contractual or employment relationship with other physicians 
at Broadway Methodist Hospital by name, race, national origin, 
sex and specialty. 

Answer: 

See answers to Interrogatories 47 - 50. 

wd 

  

 



  

65. State whether records are maintained which indicate 
the time spent by the individuals identified in the answers 

to Interrogatories 63 and 64: 

(a) if such records are maintained, identify the amount 
of time, in days, that each physician performed 
services, and specify the type of service performed 
at Gary Methodist Hospital for the following periods: 

(i) January 1, 1977 to the time these Interrogatories 
are answered; 

(1i): January 1, 1976 to December 31, 19765; 
(1ii) ~January-1l, 1975 +0 December 31,.1975; 
(iv) January 1, 1974 to December 31, 1974; 
(v} January 1, 1970 to December 31, 1970; 

(vi) January l, 1965 to December 31, 1955. 

(b) if such records are maintained, identify the amount 
of time, in days, that each physician performed 
services, and specify the type of service performed 
at Broadway Methodist Hospital for the following 

periods: 

(i). January 1, 1977 to the time these Interrogatories 

are answered; and 
(ii) ‘January 1,-1976 to December 31, .1575(sic). 

(c) if no such records are maintained, state whether 
the information requested in Interrogatory 65 (a) 
and (b) can be tabulated, and, if so privide it. 
If your answer is in the negative, state the reason 
for such answer; identify all documents which 

pertain to the information requested. 

Answer: 

The Departments in which these individuals work are generally open 
from 7 a.m. to 4:30 p.m... They are open longer hours 
when necessary depending on work load and emergency 
situations, and on weekends. Time is divided uniformly 

and informally between physicians. 

No records are kept on specific time spent by individuals. 

There are no documents pertaining to the information 

requested kept by the Hospital, and we are informed 
by the independent contractors that they do not keep 

such records. 

  

 



  

66. State the total capacity and actual complement 
of beds at Broadway Methodist Hospital, specifying, if ap- 
plicable, the department to which the beds are assigned 
(e.g., 20 beds —- obstetrics, 10 beds - ICU,etc.), and whether 
the beds are in private rooms, semi-private, 3-bed, 4-bed 
or more than 4-bed rooms: 

(a) as of the time these Interrogatories are answered; 
{b) tas of January 1X, 1977: and 
{c) as of January 1, 1976. 

  
  

  

Answer: 

Labor 
Total Room Post Special 
Beds OB Partum Medical Surgical Care 

Now 165 6 27 66 66 6 

X/3/77 165 6 27 66 66 6 

1/1/76 99 6 27 33 33 6 

The labor room is not classified as a patient bed. 

67. State the total bed capacity and actual complements 
of beds at Gary Methodist Hospital, specifying, if applicable, 
the departments or service to which the beds are assigned 
and whether the beds are in private rooms, semi-private, 
3-bed, 4-bed or more than 4-bed rooms: 

(a) as of the time these Interrogatories are answered; 
{(b) as of January 1, 1977; 
(Cc) "as OF January 1, 1976; 
(d) as of January 1, 1975; 

{ee} as of January 1, 1974; 
{f) as of Janunary 1, 1973; 
(0): as of January 1, 1972; 
(h) as of January 1, 1971; and 

(i) as of January 1, 1970. 

ali lw 

  

 



  

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Private 33" 34 34 35 40 40 41 30 

® 2-Bed Rooms 138 127 127 127 148 148 148 95 95 

3-Bed Rooms 10 10 24 24 24 24 24 27 27 

4-Bed Rooms 7 fs 7 7 7 7 7 7 7 “a 

5-Bed Rooms 0 0 0 0 1 1 1 1 1 $4 

8-Bed Rooms 0 0 0 0 0 0 2 2 2 : 

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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) 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. 

(d) 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. 

(e) with respect to emergency room patients, the number 

admitted as inpatients; 

(f) 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; 

(g) 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: 

See Exhibit No. 68. 

dG 

  

 



  

69. Describe specifically the type and number of non-medical services and 

facilities available to patients at Gary Methodist Hospital (e.g., 

telephones, color televisions, black and white televisions, radios, 

library, solarium, day room, etc). Include whether there are sufficient 

numbers of such facilities so that they may be utilized by each patient; 

and whether. why and how the number and type of services and facilities 

have changed during the periods: 

(a) from January 1, 1977 to the time these Interrogatories 

are answered; 

(b) from January 1, 1976 to December 31, 1976; 

(ic). from January 1, 1975"to December 3}, 1975; 

(d) from January 1, 1974 to December 31, 1974; 

(e) from January 1, 1973 to December 31, 1973; ay 

(fF) from January:), 1972 to December 31, 1972; 

.{q) from January 1, 1971 to December 31, 1971; 

(h) from January 1, 1970 to December 31, 1970; 

(i) from January 1, 1965 to December 31, 1965. 

GROUND FLOOR   

North Pavilion Cafeteria is used by psychiatric in-patients when ordered 

by physician. 

South Pavilion waiting area is used by out-patients. 

Street-level elevators are located in the South Pavilion entrance area 

for easy access by handicapped and patient dismissal. 

(1965, 1970-1977) 

FIRST FLOOR   

South Pavilion cafeteria is used by Rehabilitation patients for recreation 

and programs. 

(1972-1977) 

=f Oem 

  

 



: » 
» 4 

  

69. FIRST FLOOR (continued) 
  

It is also used by the Gary Board of Health, WIC (Women, Infant & Children) 

Program to interview hospital 0B Clinic patients to determine if they are 

eligible for the supplemental food program. 

(1976-1977) 

The Gary Board of Health for their Child and Youth Clinic also used,on 

a temporary basis,our clinic facilities to see their patients during re- 

modeling of their facilities. 

(1977) 

Chapel is available for patients and their family. Chaplains also visit 

patients in their rooms. 
(1965, 1970-1977) 

The Volunteer office is located on the first floor. Many services to 

patients are provided to patients by this group such as the Gift cart 

and Library cart that goes to each patient room. Florist deliveries 

are made to this office and a Volunteer delivers flowers to the patient 

room. Male volunteers provide a shaving service to patients when re- 

quested. 

Routine medical chart forms are assembled and made ready for use when 

patient is admitted. Volunteers assist with dismissal of patients and -- 

sort and deliver patient mail. | oh : : 

The Gift Shop is available for purchases by the patient. 

(1965, 1970-1977) 
\ 

Main lobby for patient visitors is located on first floor. Patients, 

who are physically able to leave nursing unit, occasionally may visit 

with their children in this area. 

(1965, 1970-1977) 

Admitting lobby is used by in-patients waiting for admission (1965, 1970- 

1977) and by out-patients for clinics such as Scoliosis and Crippled 

Children. 

(1972-1977) - 

Special Care Unit has a waiting area for patients family members. Re- 

cliner lounges are provided as family may be there for long periods of 

time. 

Televisions and telephones are not provided for patients in the Special 

Care Unit (Intensive and Coronary) for obvious reasons. 

(1965, 1970-1977) (1968-1977 in Coronary) 

In the Emergency Room area, the waiting area is used by family members 

of emergency patients, cast clinic patients, and other out-patients 

waiting to be registered. 

(1965, 1970-1977) 

5 (J 

  

 



  

69. SECOND FLOOR (continued) 
  

A paticent-visitor lounge, with nourishment station, is provided in the 
South Pavilion for the Rehabilitation patients. A color television is 
also provided. Televisions are not provided in patient rooms on this 
unit, specifically requested by the Medical Director. These patients 
are long-stay and are encouraged to use the lounge facilities and not 
isolate themselves in the patient rooms. 

(1971-1977) 

A patient-visitor lounge is provided on this floor in the North Pavilion 
also. 

(1965-1970, 1970-1977) 

Color televisions are available for all patients on this floor with the 
exception of one room. This is a four bed room and due to configuration 
of room, televisions must be mounted on bracket near each bed, rather 
than mounted on wall to allow visibility. Small televisions of this type, 
designed for hospital beds, were not available in color. Therefore, this : 
one room contains black and white televisions. 

(1977) 

Telephones are available for all patients. 

(1965,1970-1977) 

Showers are provided in Rooms 202, 204 and all patient rooms in the 
South Pavilion. Other patients share tub and shower facilities. 

(1965,1970-1977) 

..THIRD FLOOR 
  

A patient-visitor lounge, with nourishment station, is provided on this 
floor in the South Pavilion for all patients. A color television is 
provided for their use. 

0d 

(1965, 1970-1977) 

A waiting area for Fathers is provided near the Labor and Delivery area. 
(1974-1977) 

A Hothers lounge is also provided and is used for mothers classes as well. 

(1972-3977) 

Color televisions are available for all patients. There are two four bed 
rooms where black and white televisions are used as explained previously 
regarding second floor. 

(1977) 

Telephones are available for all patients. 

(1965, 1970-1977) 

Showers are provided in Rooms 302, 304, 358, 360 and all patient rooms in 
the South Pavilion. Other patients share tub and shower facilities. 

(1965, 1970-1977) 

5 

  

 



  

69. FOURTH FLOOR (continued) 
  

Waiting area is provided for out-patients attending clinics in the South 

Pavilion. 

(1965, 1970-1977) 

A Surgery Information Center (waiting area for surgery patients families) 

is provided with a television. A volunteer is stationed here to assist 

families in getting information regarding patient from Surgery, Recovery 

and the physician. 

(1966, 1970-1977) 

A lounge for patients is located 

television. Telephones and telev 

patient rooms. 

in the Psychiatric Unit with color 

isions are not provided in psychiatric 

$1965, 1970-1977] 

There is one four bed room where black and white televisions are used 

as explained previously regarding second floor. 

41972-1977) 
Color televisions are provided for surgical patients on this floor. 

(1977) 

Telephones are provided. 

(1965, 1970-1977) 

Telephones are not provided for pediatric patients but color televisions 

are provided free of charge. Black and white televisions were provided 

free of charge prior to 1977. 

(1977) 

Showers are provided in Rooms 402, L404 and all patient rooms in the South 

Pavilion. Other patients share tub and shower facilities. 

(1965, 1970-1977) a 

FIFTH FLOOR 
  

Color televisions are provided for patients on this floor which houses only 

one nursing unit. 

There is one four bed room where black and white televisions are used as 

explained previously regarding second floor. 

Telephones are available for all patients. 

(1955, 1970-1877) 

Showers are provided in Rooms 502 and 504k. All other patients share tub 

and shower facilities. 

(1965, 1970-1977) 

  

 



  

70. Describe specifically the type and number of non-medical services 

available to patients at Broadway Methodist. Include whether there 

are sufficient numbers of such facilities so that they may be utiliz- 

ed by each patient; and whether, why and how the number and type of 

services and facilities have changed during the pericds: 

(a) from January 1, 1977 to the time these Interroga- 

tories are answered; and 

(b) from January. ¥, 1976 to Dscember 31, 1976. 

GROUND FLOCR   

None 

FIRST FLOOR (1976-1977)   

Gift Shop is available for purchases by patients. This is operated by 

Volunteers. : 5 

Main lobby is available for patients and their families. On occasion, if 
a patient is physically able, he may visit children in the lobby. 

Admitting waiting is, used by patients waiting for admission. 

Volunteer office is located on this floor. Many services to patients are 

provided to patients by this group such as the Gift cart and Library cart 
that goes to each patient room. Florist deliveries are made to this office 
and a Volunteer delivers flowers to the patient room. Male volunteers pro- 

vide a shaving service to patients when requested. 

Routine medical chart forms are assembled and made ready for use when 

patient is admitted. Volunteers assist with dismissal of patients and 

sort and deliver patient mail. 

Chapel is available for patients and their family. Chaplains do visit 

patients in their room. 

Fathers waiting area is located in the labor and delivery area. 

A waiting area near the Emergency Room is used by out-patients and 

families of out-patients. 

SECOND FLOOR (1976-1977)   

A lounge near the elevators is used by patients and their families. 

-53- 

    

 



\ 

» 

  

70. SECOND FLOOR (continued) 
    

Health Education has a classroom-office that is used for patient teaching. 

A separate waiting area is provided for families of the Special Care Unit 
(Intensive and Coronary). 

All patients have available color televisions and telephones. Only one 
patient room has a shower. All other patients share tub and shower faci- 

Jities. 

THIRD FLOOR (1976-1977) 
  

A lounge near the elevators is used by patients and their families. 

All patients have available color televisions and telephones. Six of the 

sixty-six patient rooms have showers. All other patients sharc tub and 

shower facilities. 

. Ly ! 

FOURTH FLOOR (1976-1977) 
  

A lounge near the elevators is used by patients and their families. a, 

All patients have available color televisions and telephones. Three of 

the thirty-three patient rooms have showers. All other patients share 

tub and shower facilities. 

  

FIFTH FLOOR (1976-1977) 

A lounge near the elevators is used by patients and their families. 

All patients have available color televisions and telephones. Three of the 

thirty-three patient rooms have showers. All other patients share tub 

and shower facilities. 

«54 = 

  

 



  

Describe specifically the type and number of services and facilities 

available to the non-medical staff at Gry Methodist Hospital (e.g., 

cafeteria, lounges, color or black-and-white television, etc). Include 

whether these services and facilities are available to all non-medical 

staff or part of the non-medical staff and, if part, which part, how 

services and facilities and why. State whether, how and why these 

have changed during the periods: 

a) from January 1, 1977 to the time these Interrogatories 

are answered; 

(b) from January 1, 1976 to pecenlier 3%, 1976; 

(c) from January 1, 1975 to December 31, 1975; 

(d) from January 1, 1974 to December 31, 197k; 

(¢) from January 1, 1973 to December 31, 1973; ; 

(£}) from January 1, 1972 to December 31, 1372; 

{q) from January 1, 1971 to December 31, 1971; 

: {(h) from January 1, 1970 toiDecember 3}, 1570; 

(i) from January 1, 1965 to December 31, 1965. 

Locker and lounge areas for employees are located in rooms: SB20, SB24, 

B18, B20, B24, B23, B15, B6, G8D, 140, 380, 553. These are used by all 

employees. Lockers are assigned when employed through Personnel Department. 

Lockers in Surgery, Nursery, Labor & Delivery are used only by personnel 

in those departments. This is required by Board of Health. Kone of the 

employee lounges have televisions or telephones. : 

All of above in existence 1965, 1970-1977 except SB20 and SB2L which apply 

during 1971-1977. 

available for all employees during the hours it is open 

The Coffee Shop is open twenty-four hours 
The cafeteria is 

(breakfast, lunch, and dinner). 

and available for all employees. 

(1965, 1970-1977) 

Ve have a fenced employees parking lot, available to all employees. 

(1970-1977) 

A library Is'avallable for use by any employee and is located in the 

Horth Pavilion. In the past, there were two separate libraries, one for 

In 1977, the libraries were combined employees and one for physicians. 

for efficiency. 

  

 



N % » 

  

72. Describe specifically the type and number of services and facilities" 

available to the non-medical staff at Broadway Methodist Hospital. 

Include whether these services and facilities arc available to all or 

part of the non-medical staff and, if in part, how and why. State 

whether, how and why these services and facilities have changed during 

the periods: 

(a) from January 1, 1977 to the time these Interrogatories are 

answered; and 

(b) from January 1, 1976 to December 31, 1976. 

Lounge and locker areas are located in rooms: G149, G154, G230, 1140, 
Lhe 101220, 2214.5 These are used by all employees. Lockers are assigned when 

employed through Personnel Department. Lockers in Surgery, Nursery, Labor 

& Delivery are used only by personnel in those departments. This is re- 

quired by Board of Health. None of the employee lounges have telephone: 

or television. 

(1976-1977) 

The cafeteria is available to all employees for breakfast, lunch and dinner. 

A canteen (vending machine type) is available twenty-four hours. 

(1976-1977) 

le have a common parking lot that is used by employees and visitors. 

Employees usually park in the east section which is nearer employee 

entrance. 

(1976-1977) 

We have a library for use by all employees. 

(1976-1977) 

73. Describe the services and facilities available to the medical staff 

at Gary Methodist Hospital. State whether, how and why these services 

and facilities have changed during the periods: 

(a) from January 1, 1977 to the time these Interrogatories 

are answered; 

=56= 

  

 



- . 
\ 

. 

  

73. (continued) 

(b) from January 1, 1976 to December 31, 1976; 

(¢) from January 1, 1975 to December 31, 1975; 

(d) from January 1, 1974 to December 31, 1974; 

(¢) from January 1, 1973 to December 31, 1973; 

(f) from January 1, 1972 to December 31, 1972; 

(gy) from January 1, 1971 to December 31, 1971; 

(h) from January 1, 1970 to December 31, 1970; 

(i) from January 1, 1965 to December 31, 1965. 

A doctors sign-in board is located on the first floor near their lounge. 

» The lounge is adjacent to Medical Records Department for their convenience. 

Dictation booths, coat racks, reading material, etc. are provided in this 
lounge. Individual mail boxes are available for test reports, admission 
cards, etc. g on 

(1965, 1970-1977) Li | : 

A library is provided for the physicians on the first floor. 

(1965, 1970-1377) 

A doctors parking lot is limited to doctors use by key card gate. A small 
parking area, not controlled, near rear entrance of hospital is also pro- 

vided for quick access to building. 

(1965, 1970-1977) 

A call room is provided in the Emergency area for Emergency Room physicians, 

for their use only 

(1973-1977) 

A call room and locker area is provided for Obstetrical physicians in Labor 

& Delivery. 

(1965, 1970-1977) 

The Anesthesiologists have a separate work room and locker area in Surgery. 

(1965, 1970-1977) 

The Surgeons have a separate locker and lounge area. 

(1965, 1970-1977) 

The Physician Service Center provides a secretary for use by all physicians. 

She relays messages, obtains signatures, obtains information, etc. as re- 

quested by physicians. 

( 1970-1977) 

-57- 

  

 



  

73. (continued) 

A private dining room, with buffet lunch (Monday - Friday) is provided in 
the Cafeteria. Physicians are billed for their individual use of the 
service. 

(1875-1977) 

(See Addendum #1 ~- Question £73) 

74. Describe the services and facilities available to the medical staff 

at Broadway Methodist Hospital. State whether, how and why these 

services and facilities have changed during the periods: 

(a) From January 1, 1977 to the time these Interrogatories 

are answered; and 

(b) from January 1, 1976 to December 31, 1976. 

A doctors sign-in board is located on the first floor near their lounge. 
The lounge is adjacent to Medical Records for their convenience. Dictation 
booths, lockers, reading material, etc. are provided in this lounge. In- 
dividual mail boxes are provided for test reports, admission cards, etc. 

A library i.s provided for the physicians in this area also. 

A doctors parking lot is limited to doctors use by key card gate. 

A call room is provided in the Emergency area for Emergency Room physicians 
for their use only. 

Call rooms for all other physicians are provided on the second floor. 

Surgeons have a separate locker and lounge in Surgery. Obstetrical 
physicians have a separate locker and lounge area in Labor & Delivery. 

(See Addendum #2 - Question #74) 

“58 

  

 



a aX 

» 

  

Addendum #1 = Question £73 

73. Offices and/or work areas are provided for hospital-based physicians 

in the following departments: 

Muclear Medicine (1975-1977) 

. Rehabilitation (1971-1977) 
Pathology (1965, 1970-1977) 
Psychiatry (1365, 1970-1977) 
Ambulatory Clinics (1972-1977) 
Emergency Room (1973-1977) 
Intensive Care (1974-1977) 
Coronary Care (1974-1977) 
EKG {155 1970-1577) 
Electrodiagnostics (1965, 1970-1977) 

Radiology Wiig 1970-1977} 

Addendum #2 - Question #74 

74. Offices and/or work areas are provided for hospital-based physicians 

in the following departments. 

EKG (1976-1977) : 
Radiology (1976-1977) : e 
Pathology (1976-1977) 
EEG - EMG (1977) 
Nuclear Medicine (1976-1977) 
Emergency Room (1976-1977) 

Hoe 

  

 



IS 

6 Md 

  

75. Separately state any restrictions on physicians with 
staff privileges and physicians employed at Gary Methodist 

Hospital including (i) method of admission and type of patients 
at either hospital (ii) location of their offices, and (iii) 

affiliation with other hospitals. 

Answer: 

For other than "in house" positions with staff privileges, 
there are no restrictions as to method of admission 
and type of patient, location of physician's office 
or affiliation with other hospitals. 

The hospital-based physicians, such as, pathologists 
and radiologists, are restricted from admitting patients 
and such fulltime hospital-based physicians are generally 
prohibited from outside employment from other hospitals. 

To be admitted to the active medical staff, a physician 
must have an office in the general area. If a physician 
is once on the staff, he may move his office. If his 
admission of patients drops to a low level, he may 
have a change in the category of his medical staff 
membership, but this would not affect his admitting 
privileges. There is no restriction or limitation 
regarding affiliation with other hospitals. 

76. List all inpatient, outpatient clinic, ambulatory, 

emergency room, laboratory departments and services provided 

by Broadway Methodist Hospital. State whether, how and 

why these services have changed since the opening of Broadway 

Methodist Hospital. 

Answer: See Exhibit Wo. 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: 

(a) since the opening of Broadway Methodist Hospital; 

(b) from January 1, 1970 to December 31,:1975; and 

(c) from January l, 1965 to December 31, 1970. 

Answer: See Exhibit No. 71. 

-60- 

  

 



  

78. Separately list the type of surgery that is performed 
at Gary Methodist Hospital and Broadway Methodist Hospital. 

Answer: 

Surgery is categorized by the Hospital as major, minor 
and T&A (tonsillectomy and adenoids). All three categories 

of such surgery are done at both hospital locations. 

79. For each type of surgery listed in the answers 
to Interrogatory 78, separately identify for each hospital 
the number of surgery operations performed for the years 

1977, 1976, 1975,:1974 and 1973. 

  

  

Answer: 

GARY METHODIST O.R. CASES 

Majors Minors TS A 

1973 3735 3022 396 

1974 3360 3891 330 

1975 3185 3626 144 

1976 2358 2514 | 44 

1977 to date 1301 1430 8 

BROADWAY METHODIST O.R. CASES 

Majors Minors T.8 A 

1976 2227 1654 

1977 to date 17253 1345 

80. Separately list all diagnostic x-ray facilities and 

radiation facilities at Gary Methodist Hospital and Broadway 
Methodist Hospital. 

Answer: 

See Exhibits No. 80. 

=G1~ 

  

 



  

8l. Separately state the number of operating rooms 
at Gary Methodist Hospital and Broadway Methodist Hospital. 

Answer; 

There are four general surgical sultes and one cystoscopy 

room at Broadway Methodist Hospital. 

At Gary Methodist Hospital, there are five general 

surgical suites, one limited surgical suite in which 
general anesthesia is not administered, and one addi- 
tional surgical suite available but not in use at the 
present time. 

82. Describe specifically and completely the number 
and type of post-operative units and the equipment contained 
in each at Gary Methodist Hosital and Broadway Methodist 
Hospital. 

Answer: 

At Gary 

The recovery room at the Gary Hospital consists 
of 8 adult cubicles, each containing 1 cart, 1 
blood pressure cuff, 1 wall suction, 1 oxygen 
outlet. In addition, there is one cubicle for 
children containing a pediatric crib and pediatric 
blood pressure cuff. 

Additional equipment in the recovery room at Gary 
is as follows: 

adult carts 
pediatric crib 
ambu-bags (adult) 

blood pump 
cardiac monitor including defibrillator 

and crash cart 
laryngoscope with blades 

H
H
 
N
H
N
 

je
st

 

At Broadway 
  

There are’ 6 units, each containing l cart, 1 cardiac 
monitor, 1 wall oxygen outlet, 1 wall suction, 
1 blood pressure cuff, and a ceiling mounted IV 
pole. In additon, there is one isolation booth. 

Additional equipment is 2 recovery room carts 
andl crash cart. 

WE de 0 

  

 



83. List all dental and physical therapy departments 
and services provided at Gary Methodist Hospital and Broadway 
Methodist Hospital. 

  

The Indiana Rehabilitation Institute is operated as 
a department of the Hospital by Dr. Anatol Lytwakiwsky, 
M.D. The following services are offered at the respective 
locations set forth below: 

Gary Methodist Hospital: 
  

Specialized Rehabilitation Nursing 
Psychology services 
Physical Therapy 
Occupational Therapy 
Speech Therapy 
Rehabilitation Social Service 
Vocational Services 

Broadway Methodist Hospital: 
  

Physical Therapy 

Dental Therapy —- None. 

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 

years 1977, 19216,:.1975, 1974 and 11873; 
(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 

(f) 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. 

3 

  

 



  

85. State the cost per room of all rooms by type. of room 
(private, semi-private, 3-bed ward, etc.) at; 

(a) Gary Methodist Hospital; 

(1) as of the time these Interrogatories are answered; 
(11) as of January 1, 1976; 

(iii) as of January 1, 1975; and 
(iv) as of January 1, 1974; 

(b) Broadway Methodist Hospital; 

(1) as of the time these Interrogatories are answered; 
and 

(11) as of January 1, 1976. 

ANSwer: 

See Exhibits 

86. State whether Gary Methodist Hospital and Broadway 
Methodist are accredited by any governmental, regulatory 
or private agencies, associations or groups, including the 
Joint Commission on Accreditation of Hospitals (JCAH), the 
State Board of Health, the Department of the Fire Marshal 
of the State of Indiana, and the United States Department 
of Health, Education and Welfare, and, if so, state the 
names of the agencies, associations or groups. 

Answer: 

See Exhibit No. 86. 

87. Describe briefly, but completely, the dates and 
findings of the most recent reports made or issued by each 
agency, association or group set forth in the answer to 
Interrogatory 86, including whether each particular service 
reviewed was found in full, substantial or minimal compliance 
with the standards of each agency, association or group. 

Answer: 

See Exhibit No. 86 and Exhibits 87. 

Gd 

  

 



  

88. Separately state for Gary Methodist Hospital and 

Broadway Methodist Hospital all plans, procedures, regulations, 

rules and guidelines regarding the present provision of 

free services to persons unable to pay in whole or in part 

for services (either by their own resources or by third 

party reimbursement) and state whether, how and why such 

plans and procedures have changed since 1975. 

Answer: 

See Exhibit #88. Policy is the same for both hospital 

facilities. 

89. For each outpatient clinic 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 

clinic; 

(c) the major equipment and age of such equipment 

used in connection with the service; 

(d) the number of visits during each of the years 

1977, 1976, 1975, 1974 and 1973; 

(e) the physicians (not including those in training) 

assigned to each clinic (identifying by name and 

specialty and hours spent in the clinic 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); 

(f) during any one rotation the number of residents, 

interns, and externs assigned to the clinic: 

(g) the physician in charge of the overall operation 

of the clinic and the hours he (she) spent on 

a weekly basis during the most recent two complete 

fiscal years. 

Answer: 

See Exhibit Bo. 89. 

  

 



  

90. For each ambulatory service department at Gary Methodist Hospit 
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 vears.; 

(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 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 

X977,: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: 

See Exhibit 91. 

-65~- 

  

 



  

92. Describe briefly, but completely, any fund-raising 

campaigns in which Methodist Hospital, or any of its sub~ 

oranizations, agents, employees or organizations Or persons 

working in its behalf participated or are participating 

since 1965. For each such campaign state: 

(a) the name, if any, given the campaign; 

(b) the persons, groups, businesses or organizations 

responsible for organizing the campaign; 

(c) the recipients of funds received from the campaign; 

(d) the stated purpose of the campaign; 

(e) the geographical area, businesses, organizations 

and individuals from which funds were solicited 

and toward which the campaign was directed; 

(fF) the specific use to which Methodist Hospital put 

funds received. 

Answer: 

First Fund Raising Drive 

a) Gary Joint Hospital Fund, Inc. 

b) See Articles of Incorporation attached filed 

in the Secretary of State's Office 3/1/67 

C) Methodist Hospital of Gary, Inc. and St. 

Mary Mercy Hospital 

d) See articles of Incorporation 

e) Lake and Porter Counties, all businesses, 

organizations and individuals known to the 

Fund Drive were solicited 

E) New construction of the South Pavillion at 

Gary Methodist Hospital and modernization 

of equipment and facilities at Gary Methodist 

Second Fund Raising Drive 

a) Gary Joint Fund Drive, Inc. 

b) Organizers - see Articles of Incorporation 

attached filed in Secretary of State's office 

4/13/70 
C) Recipients - 50% to St. Mary Mercy Hospital 

and 50% to Methodist Hospital of Gary, Inc. 

d) Purpose - see paragraph 2 of Articles of 

Incorporation 

e) Generally Lake and Porter Counties, all businesses 

possible were contacted. 

f) As of 8/30/77 Methodist Hospital had received 

$391,500 from this drive, and said funds 

have been used for construction purposes. 

 



  

C. 

93. State, in order of descending responsibility or 
authority, the organizational units, boards, committees, 
and/or divisions which had responsibility for or authority 
over the decision to construct Broadway Methodist Hospital. 

Answer: 

BOARD OF DIRECTORS 

METHODIST HOSPITAL 

we COMMITTEE 

OF THE BOARD OF 

DIRECTORS 

FINANCE COMMITTEE OF PLANNING COMMITTEE OF 

THE BOARD OF DIRECTORS THE BOARD OF DIRECTORS 

94, List the name, race, national origin and occupation 
of members of the Board of Directors of Methodist Hospital 
and the Executive Committee of the Board of Directors for 
the years 1965 through and including 1975. 

Answer: 

See answer to Interrogatory No. 11. 

The check mark (v) in the left-hand margin indicates 
membership on the Hospital's Executive Committee. 

95. Describe briefly, but completely, when, how and 
why the decision to construct a second hospital facility, 
in addition to Gary Methodist Hospital was made. 

Answer: 

A study had been commissioned of the health care needs 
of Lake County, possibly by U. S. Steel Corporation. 
The report, which discussed and analyzed these health 
care needs was received by Methodist Hospital in 1960 
and was thereafter known as the Hamilton Report. As 
a result of the Hamilton Report, the Methodist Hospital 
Board established a Development Committee for the Hamilton 
Report. 

-67—- 

 



  

Answer to Interrogatory 95 (continuing): 
  

The Hamilton Report recommended expansion of 4 of the 
7 existing hospitals, remodelling of a 5th hospital 
and creation of a new hospital in the Crown Point area 
which would provide approximately 210 beds. This Development 
Committee of the Board of Directors met on several 
occasions with the South Lake County Hospital Development 
Corporation, consisting of concerned Crown Point residents. 
Their request was for a hospital to be operated in 
Crown Point, Indiana, by Methodist Hospital of Gary. 

At the same time a group was formed and called the 
Lake County Hospital Development Corporation. This 
group was formed by the various Chambers of Commerce 
and certain industry and business leaders in Lake County. 
The purpose of this group was to examine health care 
needs in the county and begin a county-wide fund raising 
campaign for renovation and remodelling of existing 

hospital facilities as well as construction of new hospital 
facilities where need was demonstrated. Methodist 
Hospital, as well as many other hospitals in Lake County, 
discussed this joint planning. 

In December of 1962, the Lake County Hospital Development 
Corporation received a study done by the Hospital Planning 
Council for Metropolitan Chicago. This study recommended 
that Methodist Hospital of Gary develop a satellite 
hospital north of Crown Point. 

Following receipt of this report, the Methodist Hospital 
Board in February, 1963, established a Steering Committee 
to consider the recommendation of the Metropolitan 
Chicago study. The Hospital continued meeting with 
the Lake County Hospital Development Corporation. 
The State Board of Health and the Lake County Hospital 
Development Corporation were informed of various sites 
that Methodist Hospital was examining. 

On May 2, 1963, the present site was given the highest 
priority by the Steering Committee. Thereafer there 
were discussions with the Lake County Hospital Development 
and Methodist Hospital was unable to reach agreement on 
a contract related to fund raising. 

In 1965 Methodist Hospital proceeded to acquire the 
present site. 

The decision to construct a hospital at its newly acquired 
land was deferred while a fund-raising drive was implemented 
for additions and improvements to the Gary hospital. 

Thereafter, a fund-raising drive was initiated for 
the Suburban Hospital. Both the Downtown and the Suburban 
Hospital Fund Drives received broad support from the 
community. 

In addition, See Exhibit 95. 

-68—- 

 



  

96. Describe briefly, but completely, the factors 
considered by and the decision-making process of each organizational 
unit, board, committee and/or division which determined 
the location of a second hospital facility, in addition 

to Gary Methodist Hospital. 

Answer: 

See answer to Interrogatory 95. 

97. State whether records are maintained of meetings, 
discussions, programs and other times where the decisions 
and factors set forth in the answers to Interrogatories 
95 and 96 were discussed, mentioned, considered or acted 
upon. Describe such records in a manner sufficient for 
inclusion in a Rule 34 Motion to Produce and disclose the 
name and address of the custodian in whose custody these 
records lie or attach such records to your answers to this 

discovery instrument. 

Answer 

See exhibits to answer to Interrogatory 95. 

98. Describe briefly, but completely, the factors 
considered by each organizational unit, board, committee 
and/or division which determined the initial size, nature, 
and extent of services and facilities at Broadway Methodist 
Hospital. State whether records are maintained of the meetings, 
discussions, programs and other times these factors were 
discussed, mentioned, considered or acted upon; describe 
such records in a manner sufficient for inclusion in a Rule 
34 Motion to Produce and disclose the name and address of 
the custodian in whose custody these records lie, or attach 
such records to your answers to this discovery instrument. 

Answer: 

Once the initial number of beds and the potential number 

of beds was determined by taking into account the various 

studies, the Hospital administration in conjunction 
with the architect made the determination on size, 
nature and extent of services. See correspondence 

attached as Exhibit 98-A. 

In addition, Methodist and Mercy Hospitals agreed on 
a statement of principle to avoid some duplication 
of facilities. See Exhibit 98-B. 

3 One 

 



  

99. State the geographical area served by Gary Methodist 
Hospital prior to the construction and operation of Broadway 
Methodist Hospital, the geographical area served by Gary 
Methodist Hospital since the construction and operation 
of Broadway Methodist Hospital; and the geographical area 
served by Broadway Methodist Hospital. 

Answer: 

The Hospital service area has not changed because of 
the construction of Broadway Methodist Hospital. As 
the various studies show, the Hospital service area 
prior to construction of Broadway Methodist included 
Southern Lake County and Western Porter County. The 
Hospital service area is enlarged due to the utilization 
of the linear accelerator which is a medical tool for 
a large region comprised of Northern Indiana and North- 
eastern Illinois. 

100. State whether there are any plans to enlarge 
or expand the facilities, services, number of beds, equipment 
and size of Broadway Methodist Hospital. Describe specifically 
and completely all such plans, including the projected dates 
of such plans. Describe in a manner sufficient for inclusion 
in a Rule 34 Motion to Produce all records of such plans 
and disclose the name and address of the custodian in whose 
custody these records lie, or attach such records to your 
answers to this discovery instrument. 

Answer: 

Yes. 

A Health Service Building and Laundry are planned for 
Broadway Methodist Hospital and are the subject of 
this litigation. There are no projected dates for 
such building, because of this litigation. Originally, 
the Hospital planned to let these structures out for 
bid to contractors in the Spring ofl1977. 

The Hospital has been approached by certain doctors 
for a cardiac and heart surgery center, and the Hospital 
Board has authorized its Administrator to examine this 
‘project. 

The Hospital Board has approved the construction of 
an additional 100 beds at Broadway Methodist Hospital. 
There is no projected date. The Hospital Administrator 
is custodian of all records concerning any expansion. 

Wy 7) 

 



  

101. State whether there ever was or is community 

participation in any decisions concerning the location, 

construction and plans of Broadway Methodist Hospital. 

If the answer is affirmative, list all groups of persons, 

and their location or residence, who participated, and the 

exact extent, nature and duration of such participation. 

If the answer is negative, state why there was no community 

participation. 

Answer: 

Yes. 

The location was the result of numerous meetings with 

the South Lake County Hospital Development Corporation 

(see answer to Interrogatories 95-98) and the Lake 

County Hospital Development Corporation. The construction 

and plans were dependent upon local fund raising efforts, 

which were supported generally in the community. The 

Suburban Hospital Fund Drive offices maintain records 

of community support. 

102. State whether any consideration was made or studies 

conducted concerning the economic impact, including upon 

employees, housing, office buildings and business enterprises 

Of: 

(a) the initial construction and operation of Broadway 

Methodist Hospital; and : 

(b) any plans for expansion of Broadway Methodist 

Hospital. 

If the answer is affirmative, describe the nature, extent, 

methodology and findings of all such consideration and studies. 

Describe all records of such consideration and studies in 

a manner sufficient for inclusion in a Rule 34 Motion to 

Produce, disclose the name and address of the custodian 

in whose custody these records lie, or attach all such records 

to your answers to this discovery instrument. 

Answer: 

No. The studies referred to in answer to Interrogatories 

95 - 98 generally considered whether there was or would 

be a need for a hospital in the Hobart, Ross Township- 

Merrillville area. 

w1Y wu 

 



  

103. State whether any studies were made or utilized by 
Methodist Hospital to determine the effect of the construction 
and operation of Broadway Methodist Hospital on the location 
of the offices of physicians who have, or prior to 1975 

had staff privileges or are or were employed at Gary Methodist 
Hospital; who have patients who live in Gary; and/or who 
have patients who live in South and East Lake County. If 
the answer is affirmative, describe such studies in a manner 
sufficient for inclusion in a Rule 34 Motion to Produce 
and disclose the name and address of the custodian in whose 
custody these studies lie, or attach all these studies to 
your answers. 

No study was made to determine the effect of the construction 
and cperation of Broadway Methodist Hospital on the 
location of the offices of physicians who have or prior 
to 1975 had staff privileges. 

104. State the cost of construction of Broadway Methodist 
Hospital and specifically identify the amount, source and 
nature of the funds used, including any loans, mortgages, 
contracts of insurance or guarantee or other indebtedness. 

Answer: 

The cost of construction of Broadway Methodist Hospital 
was $19,751,207.67. The source of funds used is as 
follows: 

Hill Burton Grant $ 1,152,527.00 
Mortgage Loan with Hill 

Burton Guarantee Y4,336,193.12 

Capital Provided by 
Methodist Hospital 4,262 ,487.55 

  

Total $19,751,207.67 

The applicant's share of funds includes receipts of the 
Suburban Hospital Fund Drive between Mercy and Methodist 
Hospitals, from which Methodist Hospital has received $391,500. 

105. Describe specifically the nature, extent, cost, 
source or revenue, function and effect of all renovations 
made at Gary Methodist Hospital since 1962. 

Answer: 
nn 

  

See Exhibit No. 105. 

TY De 

 



Re » 

  

92. Describes briefly, but completely, any fund-raising 

campaigns in which Methodist Hospital, or any of its sub- 

oranizations, agents, employees Or organizations Or persons 

working in its behalf participated or are participating 

since 1965. For each such campaign state: 

(a) the name, 1f any, given the campaign; 

(b) the persons, groups, businesses or organizations 

responsible for organizing the campaign; 

(c) the recipients of funds received from the campaign; 

(d) the stated purpose of the campaign; 

(e) the geographical area, businesses, organizations 

and individuals from which funds were solicited 

and toward which the campaign was directed; 

(£) the specific use to which Methodist Hospital put 

funds received. 

Answer: 

First Fund Raising Drive 

a) Gary Joint Hospital Fund, Inc. 

b) See Articles of Incorporation attached filed 

in the Secretary of State's Office 3/1/67 

C) Methodist Hospital of Gary, Inc. and St. 

Mary Mercy Hospital 

d) See articles of Incorporation 

e) I,ake and Porter Counties, all businesses, 

organizations and individuals known to the 

Fund Drive were solicited 

f) New construction of the South Pavillion at 

Gary Methodist Hospital and modernization 

of equipment and facilities at Gary Methodist 

Second Fund Raising Drive 

a) Gary Joint Fund Drive, Inc. 

b) Organizers - see Articles of Incorporation 

attached filed in Secretary of State's office 

4/13/70 

C) Recipients - 50% to St. Mary Mercy Hospital 

and 50% to Methodist Hospital of Gary, Inc. 

d) Purpose - see paragraph 2 of Articles of 

Incorporation 

e) Generally Lake and Porter Counties, all businesses 

possible were contacted. 

£) As of 8/30/77 Methodist Hospital had received 

$391,500 from this drive, and said funds 

have been used for construction purposes. 

RC dh. A 
E 

  

 



  

C. 

93. State, in order of descending responsibility or 
authority, the organizational units, boards, committees, 
and/or divisions which had responsibility for or authority 
over the decision to construct Broadway Methodist Hospital. 

Answer: 

BOARD OF DIRECTORS 

METHODIST HOSPITAL 

3 COMMITTEE 

OF THE BOARD OF 

DIRECTORS 

FINANCE COMMITTEE OF PLANNING" COMMITTEE OF 

THE BOARD OF DIRECTORS THE BOARD OF DIRECTORS 

94. List the name, race, national origin and occupation 
of members of the Board of Directors of Methodist Hospital 
and the Executive Committee of the Board of Directors for 
the years 1965 through and including 1975. 

Answer : 

See answer to Interrogatory No. 11. 

The check mark (v) in the left-hand margin indicates 
membership on the Hospital's Executive Committee. 

95. Describe briefly, but completely, when, how and 
why the decision to construct a second hospital facility, 

in addition to Gary Methodist Hospital was made. 

Answer: 

A study had been commissioned of the health care needs 
of Lake County, possibly by U. 8. Steel Corporation. 
The report, which discussed and analyzed these health 
care needs was received by Methodist Hospital in 13960 
and was thereafter known as the Hamilton Report. As 
a result of the Hamilton Report, the Methodist Hospital 
Board established a Development Committee for the Hamilton 

Report. 

—-67— 

  

 



  

Answer to Interrogatory 95 (continuing): 
  

The Hamilton Report recommended expansion of 4 of the 
7 existing hospitals, remodelling of a 5th hospital 
and creation of a new hospital in the Crown Point area 
which would provide approximately 210 beds. This Development 
Committee of the Board of Directors met on several 
occasions with the South Lake County Hospital Development 
Corporation, consisting of concerned Crown Point residents. 
Their request was for a hospital to be operated in 
Crown Point, Indiana, by Methodist Hospital of Gary. 

At the same time a group was formed and called the 
Lake County Hospital Development Corporation. This 

group was formed by the various Chambers of Commerce 
and certain industry and business leaders in Lake County. 
The purpose of this group was to examine health care 
needs in the county and begin a county-wide fund raising 
campaign for renovation and remodelling of existing 
hospital facilities as well as construction of new hospital 
facilities where need was demonstrated. Methodist 
Hospital, as well as many other hospitals in Lake County, 
discussed this joint planning. 

In December of 1962, the Lake County Hospital Development 
Corporation received a study done by the Hospital Planning 
Council for Metropolitan Chicago. This study recommended 

that Methodist Hospital of Gary develop a satellite 
hospital north of Crown Point. 

Following receipt of this report, the Methodist Hospital 
Board in February, 1963, established a Steering Committee 
to consider the recommendation of the Metropolitan 
Chicago study. The Hospital continued meeting with 
the Lake County Hospital Development Corporation. 
The State Board of Health and the Lake County Hospital 
Development Corporation were informed of various sites 
that Methodist Hospital was examining. 

On May 2, 1963, the present site was given the highest 
priority by the Steering Committee. Thereafer there 
were discussions with the Lake County Hospital Development 
and Methodist Hospital was unable to reach agreement on 

a contract related to fund raising. 

In 1965 Methodist Hospital proceeded to acquire the 
present site. 

The decision to construct a hospital at its newly acquired 
land was deferred while a fund-raising drive was implemented 
for additions and improvements to the Gary hospital. 

Thereafter, a fund-raising drive was initiated for 
the Suburban Hospital. Both the Downtown and the Suburban 
Hospital Fund Drives received broad support from the 

community. 

In addition, See Exhibit 95.7 

-68- 

  

 



  

4 8 : 

96. Describe briefly, but completely, the factors 

considered by and the decision-making process of each organizational 

unit, board, committee and/or division which determined 

the location of a second hospital facility, in addition 

to Gary Methodist Hospital. 

Answer: 

See answer to Interrogatory 95. 

97. State whether records are maintained of meetings, 

discussions, programs and other times where the decisions 

and factors set forth in the answers to Interrogatories 

55 and 96 were discussed, mentioned, considered or acted 

upon. Describe such records in a manner sufficient for 

inclusion in a Rule 34 Motion to Produce and disclose the 

name and address of the custodian in whose custody these 

records lie or attach such records to your answers to this 

discovery instrument. 

Answer 

See exhibits to answer to Interrogatory 95. 

98. Describe briefly, but completely, the factors 

considered by each organizational unit, board, committee 

and/or division which determined the initial size, nature, 

and extent of services and facilities at Broadway Methodist 

Hospital. State whether records are maintained of the meetings, 

discussions, programs and other times these factors were 

discussed, mentioned, considered or acted upon; describe 

such records in a manner sufficient for inclusion in a Rule 

34 Motion to Produce and disclose the name and address of 

the custodian in whose custody these records lie, or attach 

such records to your answers to this discovery instrument. 

Answer: 

Once the initial number of beds and the potential number 

of beds was determined by taking into account the various 

studies, the Hospital administration in conjunction 

with the architect made the determination on size, 

nature and extent of services. See correspondence 

attached as Exhibit 98-A. 

In addition, Methodist and Mercy Hospitals agreed on 

a statement of principle to avoid some duplication 

of facilities. Sce Exhibit 98-B. 

-69- 

  

 



  

99. State the geographical area served by Gary Methodist 
Hospital prior to the construction and operation of Broadway 
Methodist Hospital, the geographical area served by Gary 
Methodist Hospital since the construction and operation 
of Broadway Methodist Hospital; and the geographical area 
served by Broadway Methodist Hospital. 

Answer: 

The Hospital service area has not changed because of 
the construction of Broadway Methodist Hospital. As 
the various studies show, the Hospital service area 
prior to construction of Broadway Methodist included 
Southern Lake County and Western Porter County. The 
Hospital service area is enlarged due to the utilization 
of the linear accelerator which is a medical tool for 
a large region comprised of Northern Indiana and North- 
eastern Illinois. 

100. State whether there are any plans to enlarge 
or expand the facilities, services, number of beds, equipment 
and size of Broadway Methodist Hospital. Describe specifically 
and completely all such plans, including the projected dates 
of such plans. Describe in a manner sufficient for inclusion 
in a Rule 34 Motion to Produce all records of such plans 
and disclose the name and address of the custodian in whose 
custody these records lie, or attach such records to your 
answers to this discovery instrument. 

Answer: 

Yes. 

A Health Service Building and Laundry are planned for 
Broadway Methodist Hospital and are the subject of 
this litigation. There are no projected dates for 
such building, because of this litigation. Originally, 
the Hospital planned to let these structures out for 
bid to contractors in the Spring o0£1977. 

The Hospital has been approached by certain doctors 
for a cardiac and heart surgery center, and the Hospital 
Board has authorized its Administrator to examine this 
project. 

The Hospital Board has approved the construction of 
an additional 100 beds at Broadway Methodist Hospital. 
There is no projected date. The Hospital Administrator 
is custodian of all records concerning any expansion. 

TF) 

  

 



  

101. State whether there ever was or is community 

participation in any decisions concerning the location, 

construction and plans of Broadway Methodist Hospital. 

If the answer is affirmative, list all groups of persons, 

and their location or residence, who participated, and the 

exact extent, nature and duration of such participation. 

If the answer is negative, state why there was no community 

participation. 

Answer: 

Yes. 

The location was the result of numerous meetings with 

the South Lake County Hospital Development Corporation 

(see answer to Interrogatories 95-98) and the Lake 

County Hospital Development Corporation, The construction 

and plans were dependent upon local fund raising efforts, 

which were supported generally in the community. The 

suburban Hospital Fund Drive offices maintain records 

of community support. 

102. State whether any consideration was made or studies 

conducted concerning the economic impact, including upon 

employees, housing, office buildings and business enterprises 

cf: 

(a) ‘the initial construction and operation of Broadway 

Methodist Hospital; and : 

(hb) . any plans. for expansion of Broadway Methodist 

Hospital. 

If the answer is affirmative, describe the nature, extent, 

methodology and findings of all such consideration and studies. 

Describe all records of such consideration and studies in 

a manner sufficient for inclusion in a Rule 34 Motion to 

Produce, disclose the name and address of the custodian 

in whose custody these records lie, Or attach all such records 

to your answers to this discovery instrument. 

Answer: 

No. The studies referred to in answer to Interrogatories 

95 —- 98 generally considered whether there was Or would 

be a need for a hospital in the Hobart, Ross Township- 

Merrillville area. 

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103. State whether any studies were made or utilized by 
Methodist Hospital to determine the effect of the construction 
and operation of Broadway Methodist Hospital on the location 
of the offices of physicians who have, or prior to 1975 
had staff privileges or are or were employed at Gary Methodist 
Hospital; who have patients who live in Gary; and/or who 
have patients who live in South and East Lake County. If 
the answer is affirmative, describe such studies in a manner 
sufficient for inclusion in a Rule 34 Motion to Produce 
and disclose the name and address of the custodian in whose 
custody these studies lie, or attach all these studies to 

your answers. 

No study was made to determine the effect of the construction 
and operation of Broadway Methodist Hospital on the 
location of the offices of physicians who have or prior 

to 1975 had staff privileges. 

104. State the cost of construction of Broadway Methodist 
Hospital and specifically identify the amount, source and 
nature of the funds used, including any loans, mortgages, 
contracts of insurance or guarantee or other indebtedness. 

Answer: 

The cost of construction of Broadway Methodist Hospital 

was $19,751,207.67. The source of funds used is as 

follows: 

Hill Burton Grant $1,152,527.00 
Mortgage Loan with Hill 

Burton Guarantee 34,336,193.12 

Capital Provided by 
Methodist Hospital 4,262,487 .55 

  

Total $19,751,207.67 

The applicant's share of funds includes receipts of the 
Suburban Hospital Fund Drive between Mercy and Methodist 
Hospitals, from which Methodist Hospital has received $391,500. 

105. Describe specifically the nature, extent, cost, 
source or revenue, function and effect of all renovations 
made at Gary Methodist Hospital since 1962. 

Answer: 

See Exhibit No. 105. 

=F Jo 

  

 



  

106. State the gross patient revenues by inpatient, 
outpatient, clinic, ambulatory service and emergency room: 

(a) for the years 1977, 1976, 1975, 1974, 1973 and 

1970 for Gary Methodist Hospital; 
(b) for the years 1977 and 1976 for Broadway Methodist 

Hospital. 

Answer: 

    

Gary Methodist Hospital 
  

1977 (As of July 31,.1977) 

Inpatient - $10,098,749 

  

Included in this figure are: 
Emergency Room - $ 46,100 
Clinics - $ -0- 
Ambulatory Care - $ -0- 

Outpatient W $1,268,716 

Included in this figure are: 
Emergency Room - $ 448,070 
Clinics ~8 62,516 
Ambulatory Care - -0- 

1976 

Inpatient - $16,813.29 

Included in this figure are: 
Emergency Room - $76,131 
Clinics - ~-0- 
Ambulatory Care - ad {i 

Outpatient nr $1,962,985 

Included in this figure are: 
Emergency Room - § 735,485 
Clinics - 64,640 
Ambulatory Care - -Q- 

2975 

Inpatient - $16,607,796 

Included in this figure are: 
Emergency Room - $71,667 
Clinics - -0- 
Ambulatory Care -— a he 

Outpatient $1,890,653 

Included in this figure are: 
Emergency Room - & 672,814 

Clinics - 116,515 
Ambulatory Care - ut { dee 

-73=- 

 



  

Answer to Interrogatory 106 (continuing): 
  

1974 

Inpatient 

Outpatient 

1973 

Inpatient 

Outpatient 

1970 

Inpatient 

Outpatient 

$13,608,496 

Included in this figure are: 

Emergency Room - S$ 47,219 

Clinics - -0- 

Ambulatory Care = (0 

$1,146,853 

Included in this figure are: 
Emergency Room - $ 163,573 
Clinics - 15,479 
Ambulatory Care m- lyon 

$12,369,209 

Included in this flgure are: 

Emergency Room ~ 539,072 
Clinics - -0- 

Ambulatory Care - -0- 

$1,071,782 

Included in this figure are: 
Emergency Room - $172,178 
Clinics - 10,678 
Ambulatory Care - -0- 

$8,827,164 

Included in this figure are: 
Emergency Room - $$ 28,977 
Clinics - -(- 

Ambulatory Care - out { Lo 

$938,615 

Included in this figure are: 

Emergency Room - $132,968 

Clinics -— -0~- 

Ambulatory Care -— = 

Why 0 

 



  

Answer to Interrogatory 106 (continuing): 
  

Broadway Methodist Hospital 
  

1977 (As Of July 31, 1977) 

Inpatient os $3,668,787 

Included in this figure are: 
Emergency Room - 8 25,584 
Clinics -— -0- 
Ambulatory Care - -0 

Outpatient - 3 793,701 

Included in this figure are: 
. Emergency Room - $170,221 
Clinics - 2,716 
Ambulatory Care — -0 

1976 

Inpatient - $9,411,025 

Included in this figure are: 
Emergency Room - § 32,728 
Clinics - -0~- 
Ambulatory Care - -0- 

Outpatient - $1,022,696 

Included in this figure are: 
Emergency Room - $194,107 
Clinics - 626 
Ambulatory Care - 0 

NOTE: The figures for 1977 are taken from the Hospital 
Monthly Financial Reports. All other figures are 
taken from the Ernst & Ernst Audited Financial Reports. 

-75- 

 



4 

  

107. State the gross patient revenues, broken down 
by inpatient, outpatient, clinic, ambulatory service and 

emergency room under the Medicare and Medicaid program: 

(a) for the years 1977, 1976, 1975, 1974, 1973 and 

1970 for Gary Methodist Hospital; 
(b) for the years 1977 and 1976 for Broadway Methodist 

  

    

  
    

  

    

      

Hospital. 

Answer: 

Medicare 

Broadway ss ; Gary 

Inpatient Outpatient Inpatient Outpatient 

1977 2,202,020 144,218 2,384,474 83,195 
1976 2,747,539 177,155 3,180,896 111,008 
1975 N/A N/A 3,254,451 108,673 
1974 N/A N/A 2+570,121 73,721 
1973 N/A N/A 2,031,874 65,797 
1970 N/A N/A 1,549,481 68,247 

Medicaid 

Broadway Gary 

Inpatient Outpatient Inpatient Outpatient 

1977 194,111 29,416 2,156,030 284,399 
1976 373,587 25,730 3,260,400 382,481 
1975 N/A N/A 2,457,504 364,761 
1974 N/A N/A 2:129,288 197,948 
Jo73 N/A N/A 1,896,346 
1970 N/A N/A 451,194 

Taken from Patient Revenue Usage; As of Aug. 31, 1977 

108. State whether any Federal or State agency, since 
1965, has made an "on-site" investigation or review of Gary 
Methodist Hospital and/or Broadway Methodist Hospital with 
respect to compliance with Title VI of the Civil Rights 
Act of 1964. If the answer is affirmative, state the approximate 
date of such inspections and the findings made as a result. 

Answer: 

See Exhibit 108. 

ut fe 

 



  

106. State the gross patient revenues by inpatient, 

outpatient, clinic, ambulatory service and emergency room: 

(a) for the years 1977, 1976, 1975, 1974, 1973 and 

1970 for Gary Methodist Hospital; 

(b) for the years 1977 and 1976 for Broadway Methodist 

Hospital. 

Answer: z 
Gary Methodist Hospital 
  

1971 (As. of July 31, 1977) 

Inpatient $10,098,749 

Included in this figure are: 
Emergency Room - $46,100 
Clinics - $ ~-0- 
Ambulatory Care - $ -0- 

Outpatient $1,268,716 

Included in this figure are: 
Emergency Room - S$ 448,070 
Clinics -8 62,516 
Ambulatory Care - -0—- 

1976 

Inpatient $16,813.29 

Included in this figure are: 
Emergency Room - 8 76,131 
Clinics — -0- 
Ambulatory Care - ~~ 

Outpatient $1,962,985 . 

Included in this figure are: 
Emergency Room - § 735,485 
Clinics - 64,640 
Ambulatory Care - -Q- 

1975 

Inpatient $16,607,796 

Included in this figure are: 
Emergency Room - 8 71,687 
Clinics - -0- 
Ambulatory Care - a | ho 

Outpatient $1,890,653 

Included in this figure are: 
Emergency Room - $$ 672,814 
Clinics - 316,516 
Ambulatory Care - -0- 

-73- 

  

 



  

Answer to Interrogatory 106 (continuing): 
  

  

1974 

Inpatient $13,608,496 

> included in this figure are: 

Emergency Room - S$ 47,219 

Clinics - -0Q 

Ambulatory Care - -{) 

Outpatient ne $1,140,853 

Tncluded in this figure are: 

Emergency Room - 8S 168,573 

Clinics - 15,479 

Ambulatory Care - od ¥ Ju 

1973 

Inpatient - $12,369,209 

Included in this figure are: 

Emergency Room = 35.39,972 

Clinics - 10 -0- 

Ambulatory Care - -0— 

Outpatient - $1,071,782 

Included in this figure are: 

Emergency Room - $172,178 

Clinics - 10,678 

Ambulatory Care - -0~- 

1970 

Inpatient - $8,827,164 

Included in this figure are: 

Emergency Room - 8 28,977 

Clinics — ~0- 

Ambulatory Care - ot ¢ Eo 

Outpatient - $938,615 

included in this figure are: 

Emergency Room - $132,968 

Clinics - -0- 

Ambulatory Care - -) 

We 

  

 



  

Answer to Interrogatory 106 (continuing): 
  

Broadway Methodist Hospital 
  

1977 {As of:July 31, 1977) 

Inpatient - . $3,668,787 

Included in this figure are: 
Emergency Room - § 25,584 
Clinics -— -0- 
Ambulatory Care - -0- 

Outpatient - 3:793,701 

Included in this figure are: 
Emergency Room -2170,221 
Clinics - 2,716 
Ambulatory Care — a 

1976 

Inpatient - $9,411,025 

Included in this figure are: 
Emergency Room - 8 32,728 
Clinics - -0- 
Ambulatory Care - wt Liu 

Outpatient - $1,022,695 

Included in this figure are: 
Emergency Room - $194,107 
Clinics - 626 
Ambulatory Care — -0 

NOTE: The figures for 1977 are taken from the Hospital 
Monthly Financial Reports. All other figures are 
taken from the Ernst & Ernst Audited Financial Reports. 

-75~- 

  

 



  

107. State the gross patient revenues, broken down 
by inpatient, outpatient, clinic, ambulatory service and 

emergency room under the Medicare and Medicaid program: 

(a) for the vears 1977,:1976, 1975,..1974, 1973 and 
1970 for Gary Methodist Hospital; 

(b) for the years 1977 and 1976 for Broadway Methodist 

  

    

        

  

    

      

Hospital. - 

Answer: 

Medicare 

Broadway | | Gary 

Inpatient Outpatient Inpatient Outpatient 

1977 2,202,020 144,218 2,384,474 83,195 
1976 2:7417,533 377,155 3,180,896 111,008 
1975 N/A N/A 3,254,451 108,673 
1974 N/A N/A 2,570,121 23,721 
1973 N/A N/A 2,031,874 65,797 
1970 N/A N/A 1,549,481 68,247 

Medicaid 

Broadway Gary 

Inpatient Outpatient Inpatient Outpatient 

1977 194,111 29,416 2,156,030 234,399 
1976 373,587 25,730 3,260,400 382,481 
1975 N/A N/A 2,457,504 364,761 
1974 N/A N/A 2:129,28838 197,948 
1973 N/A N/A 1,896,346 
1970 N/A N/A 451,194 

Taken from Patient Revenue Usage; As of Aug. 31, 1977 

108. State whether any Federal or State agency, since 
1965, has made an "on-site" investigation or review of Gary 
Methodist Hospital and/or Broadway Methodist Hospital with 
respect to compliance with Title VI of the Civil Rights 
Act of 1964. If the answer is affirmative, state the approximate 
date of such inspections and the findings made as a result. 

Answer: 

See Exhibit 108. 

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