November 5, 2023

Mayor Brandon Johnson

121 N LaSalle Street
Chicago City Hall 4th Floor
Chicago, IL 60602

Dear Mayor Johnson:

The Association of Safety-Net Community Hospitals (ASNCH), on behalf of its member safety-net
hospitals across the City of Chicago, is extremely concerned about the consequences of the proposed
Chicago Paid Leave Ordinance, currently being negotiated by your administration. Safety-net hospitals
provide quality healthcare to low-income communities across Chicago who would otherwise lack
adequate resources and access to care. Safety-net hospitals are also the economic engines of the
poorest communities with the highest unemployment rates in our entire state.

Due to their payer-mix, safety-net hospitals are almost wholly reliant on the state of Illinois and the
Medicaid Program for funding and do not have the ability to offset losses on commercial payers. After
performing individual financial analyses, it is projected that for a safety-net hospital with 650
employees, this proposed ordinance would cost the hospital $2 million annually. This additional
financial burden will force the Chicago safety-net hospitals to make the incredibly difficult decision to
either find new revenues from the state of Illinois to cover this cost, or to reduce staff and eliminate
services they provide to some of the most vulnerable people in the city, who are reliant on them for
basic healthcare.

Specifically, the ordinance would require safety-net hospitals to do the following:

• In order to implement, safety-nets would have to spend hundreds of thousands of dollars to

retool our current paid time off system and tracking mechanisms.

• Hospitals have a category of employees called “on call employees”, who only come into work
when needed. Requiring hospitals to accrue and pay-out sick time for these employees (who
may only work a few hours per month) will require additional time and expenses for hospital
departments, especially accounting.

• Safety-net hospitals are disproportionately reliant on agency staff to be able to provide care to
patients. The cost of these agencies has already increased safety-net hospitals labor cost by
over 30%. This ordinance will further increase the cost of operations for agency staff.

• Being required to hold reserves for and pay out sick pay at the time of separation (which is not
done anywhere else in the country) will cripple safety-net hospitals who are already facing
significant fiscal deficits without any increased revenues.

• Safety-net hospitals employ a class of nurses, called “in-house registry”, which are nurses that
do not want any benefits, as they accrue benefits elsewhere with another employer. These
employees are paid more per hour because they do not want to be employed full-time and
receive benefits through other employers. The increased cost, as proposed by this ordinance,

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 will push the cost close to the current cost of agency nurses. These same employees will also
now have to be provided benefits and gain the same benefits at different organizations at the
same time.

We are unsure if the City of Chicago truly understands or appreciates the dire financial position of
safety-net hospitals, who are faced with tough decisions daily to provide underserved communities
with the care that they deserve. We ask that you have a conversation with us, as well as with our
legislative champions in the Illinois General Assembly, who have fought to protect the funding needed
for safety-nets on an annual basis.

Safety-net hospitals are the largest employers in the poorest communities, as well as beacons of care
for the underserved and the underprivileged. We also ask that you consider these factors when making
decisions that would cause incredible harm to the ability of these hospitals to maintain operations and
provide care.

We ask that you please remove safety-net hospitals, as defined in Illinois state law, from the proposed
ordinance to help protect the critical healthcare services they provide to residents.

Sincerely,

José R. Sánchez
President and CEO, Humboldt Park Health
Chairman, Association of Safety-Net Community Hospitals