DRHS' Board of Directors will be required to sign a conflict of interest agreement in which they will agree to disclose annually any conflicts they may have. DRHS' Board of Directors will be required to agree each year to support and work towards Mercy's goals and values. DRHS' Board of Directors will be required to abstain from a Board vote where they have a conflict of interest. An authorized representative of Mercy has stated that it is speculation to make hospital budget projections beyond three years. An authorized representative of Mercy has stated that it is speculation to make projections about efficiencies from the proposed consolidation beyond a three-year period.
Defendants have no present plans to make DRHS into a tertiary care hospital.
An authorized representative of Mercy has stated that managed care plans use financial incentives to pressure hospitals to be as efficient as possible. Page 6 26. An authorized representative of Mercy has stated that managed care plans leverage Mercy against other hospitals to obtain lower rates for hospital services. Hospitals outside Dubuque are not as convenient as Mercy and Finley for Dubuque residents. An authorized representative of Finley has stated that one significant reason Dubuque residents seek hospital services in Cedar Rapids, Iowa City, or Madison is that they need tertiary or specialized services not available at Finley or Mercy.