CERTIFICATE OF NEED APPLICATION

The Grove in Frontenac

86-Bed Assisted Living Facility
Project No. 5047 RS

submitted to

Missouri Health Facilities Review Committee

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DIVIDER I

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I.1

Applicant Identification and Certification

See Attachment I.1.

I.2

Representative Registration

See Attachment I.2.

I.3

Proposed Project Budget

See Attachment I.3a and I.3b.

Proposed Project Budget Detail Sheet
1.

New Construction Costs The hard construction costs for this project are
budgeted at $13,818,000.

4.

Architect/Engineering Fees The budgeted cost for such fees is $775,000.

5.

Other Equipment - $900,000. This cost includes fixtures, furnishings, non-major

medical equipment, common areas and other spaces.

7.

Land Acquisition Costs - $2,800,000.

8.

Consultants Fees / Legal Fees the budgeted cost for such fees is $665,462.

9.

Interest During Construction The anticipated interest during construction is

$327,510. This is based on a 12-month construction period.

10.

Other Costs The budgeted figure for other costs is $4,301,647. Included in this
figure are financial costs, development fees, pre-open marketing, contingency,
and operational deficit.

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Attachment I.1
Certificate of Need Program

APPLICANT IDENTIFICATION AND CERTIFICATION

The information provided must match the Letter of Intent for this project, without exception.

1. Project Location

(Attach additional pages as necessary to identify multiple project sites.)

Project Number

Title of Proposed Project

5047 RS

The Grove in Frontenac

Project Address (Street/City/ State/Zip Code)

County

St. Louis

1400 S. Spoede Road and 1396 S. Spoede Road, St. Louis, Missouri 63131

2. Applicant Identification
List All Owner(s):

(Information must agree with previously submitted Letter of Intent.)

Telephone Number

Address (Street/City/State/Zip Code)

(List corporate entity.)

The Grove Assisted Living, L.L.C.

636-532-5533

1795 Clarkson Rd., Suite 190, Chesterfield, MO 63017

(List entity to be

List All Operator(s):

The Grove Assisted Living, L.L.C.

3. Ownership

Telephone Number

Address (Street/City/State/Zip Code)

licensed or certified.)

1795 Clarkson Rd., Suite 190, Chesterfield, MO 63017

636-532-5533

(Check applicable category.)

Nonprofit Corporation

El Partnership

Individual

City

District

Corporation

County

121 Other

LLC

4. Certification
In submitting this project application, the applicant understands that:
(A) The review will be made as to the community need for the proposed beds or equipment in this
application;
(B) In determining community need, the Missouri Health Facilities Review Committee (Committee) will
consider all similar beds or equipment within the service area;
(C) The issuance of a Certificate of Need (CON) by the Committee depends on conformance with its Rules
and CON statute;
(D) A CON shall be subject to forfeiture for failure to incur an expenditure on any approved project six (6)
months after the date of issuance, unless obligated or extended by the Committee for an additional six
(6) months:
(E) Notification will be provided to the CON Program staff if and when the project is abandoned; and
(F) A CON, if issued, may not be transferred, relocated, or modified except with the consent of the
Committee.
We certify the information and date in this application as accurate to the best of our knowledge and belief by our
representative's signature below:

5. Authorized Contact Person

(Attach a Contact Person Correction Form if different from the Letter of Intent.)

Name of Contact Person

Title

Legal Counsel

Jonathan F. Dalton
Telephone Number

Fax Number

E-mail Address

314-259-4702

314-552-4861

jdaltonaarmstrongteasdale.com

Signature of Contac

Date of Signature

f
if /41--

4.1 'ISM *

MO 580-1861 (03/1

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0/ 4.1

Attachment I.2
Certificate of Need Program

REPRESENTATIVE REGISTRATION
(A registration form must be completed for each project presented.)
Project Name

Number

The Grove in Frontenac

5047 RS
(Please type or print legibly.)
Title

Name of Representative

Legal Counsel

Jonathan F. Dalton
Firm/Corporation/Association of Representative (may be different from below, e.g., law fu -m, consultant, other)

Telephone Number

Armstrong Teasdale LLP

314-259-4702

Address (Street/City/State/Zip Code)

7700 Forsyth Blvd., Suite 1800, St. Louis, Missouri 63105

Who's interests are being represented?
(If more than one, submit a separate Representative Registration Form for each.)
Name of Individual/Agency/Corporation/Organization being Represented

Telephone Number

The Grove Assisted Living, L.L.C.

636-532-5533

Address (Street/City/State/Zip Code)

1795 Clarkson Road, Suite 190, Chesterfield, Missouri 63017

Relationship to Project:

Check one. Do you:

121

None

Oppose

Employee

Neutral

Z Legal Counsel

Support

Consultant
Lobbyist
Other (explain):

Other Information:

I attest that to the best of my belief and knowledge the testimony and information presented by
me is truthful, represents factual information, and is in compliance with 197.326.1 RSMo
which says: Any person who is paid either as part of his normal employment or as a lobbyist to
support or oppose any project before the health facilities review committee shall register as a
lobbyist pursuant to chapter 105 RSMo, and shall also register with the staff of the health
facilities review committee for every project in which such person has an interest and indicate
whether such person supports or opposes the named project. The registration shall also include
the names and addresses of any person, firm, corporation or association that the person
registering represents in relation to the named project. Any person violating the provisions of this
subsection shall be su ect to the penalties specified in 105.478, RSMo.
Original Signature

MO 580-1869 (11/01)

Date

71
/

A-1 -2(. 2a/5e

Vf

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Attachment I.3.a
Certificate of Need Program

$2,800,000
$665,462
$327,510
$4,301,647

$9,769,619

$23,587,619

PROPOSED PROJECT BUDGET

$4,717,524
$0

$18,870,095
$0

$23,587,619

69,090

$0

$200
0
$0

Description

Dollars

COSTS:*

(Fill in every line,

even if the
$0amount is $0.)
$13,818,000
$13,818,000

1. New Construction Costs ***

$775,000

2. Renovation Costs ***

$900,000

3. Subtotal Construction Costs (#1 plus #2)

4. Architectural/Engineering Fees
5. Other Equipment (not in construction contract)
6. Major Medical Equipment
7. Land Acquisition Costs ***
8. Consultants Fees/Legal Fees ***
9. Interest During Construction ***
10. Other Costs ****
11. Subtotal Non-Construction Costs (sum of #4 through #10)
12. Total Project Development Costs (#3 plus #11)

**

FINANCING:
13. Unrestricted Funds
14. Bonds
15. Loans
16. Other Methods (specify: __________________________________)
17. Total Project Financing (sum of #13 through #16)

**

18. New Construction Total Square Footage

19. New Construction Costs Per Square Foot *****
20. Renovated Space Total Square Footage
21. Renovated Space Costs Per Square Foot ******

Attach additional page(s) detailing how each line item was determined, including all methods and
assumptions used. Provide documentation of all major costs. For major medical equipment, refer to
19 CSR 60-50.300 (11) for inclusion of costs.

** These amounts should be the same.

*** Capitalizable items to be recognized as capital expenditures after project completion.
**** Include as Other Costs the following: other costs of financing; the value of existing lands, buildings and
equipment not previously used for health care services, such as a renovated house converted to residential
care, determined by original cost, fair market value, or appraised value; or the fair market value of any
leased equipment or building, or the cost of beds to be purchased.
***** Divide new construction costs by total new construction square footage.
****** Divide renovation costs by total renovation square footage.
MO5801863(08/13)

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Attachment I.3.b

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DIVIDER II

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II.1

Detailed Project Description

The Grove Assisted Living, L.L.C. proposes to develop and operate an 86-bed, 69,090 square
foot, Assisted Living Facility on a site located at 1400 S. Spoede Road and 1396 S. Spoede
Road, St. Louis, Missouri 63131. Thirty-five (35) beds have been designated for memory care.
The total project cost is $23,587,619.
The facility will be offered on a monthly rental basis with no buy-in fees. The facility will have
a combination of studios, one, and two bedroom units.
The community will provide the following amenities:

Salon
Spa
Dining Room
Exercise Room
Outdoor Gardens
Private Diving
Wellness Center
Lounges
Transportation
First Class Service

II.2

Timeline of Events

Construction on the facility is expected to begin in January 2015. Construction will take
approximately 18 months. The facility is expected to open in August 2016, with 2017 as its first
full calendar year of operations.

II.3

Map Showing Location of Proposed Facility

See Attachment II.3.

II.4-5 Site Plan and Preliminary Schematic Drawings for Proposed Project
See Attachment II.4-5

II.6

Evidence that Architectural Plans have been Submitted to DHSS

See Attachment II.6.

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II.7

Gross Square Footage

The proposed square footage for the new facility is 69,090.

II.8

Document Ownership of the Project Site

See Attachment II.8.

II.9

Description of the Community to be Served

Elderly residents desire to stay in the community in which they have lived for many years. Many
times these residents have raised their family in a particular community, and would like to stay in
such places where they have had wonderful experiences. This allows them to stay engaged with
religious organizations and the community.
This is very true for the residents in Frontenac and the surrounding communities. These
communities are closely knit with a strong following. Their residents tend to be very loyal to
their local community and are reluctant to relocate to another area. The close proximity of retail,
universities, and healthcare make this a desirable location for residents to continue to interact
with the community.
Based in these factors, the applicant believes that the community to be served will be people
aged 65 and over who reside within the communities surrounding this location who are in need
of assisted living services.

II.10 2015 Population Projection for the 15-mile Radius Service Area
The projected 2015 65+ population for the 15-mile radius service area has been calculated in
accordance with Missouri regulations to be 227,329.
See Attachment II.10a through 11.10f for the supporting documentation for this calculation..

II.11 Specific Community Problems and Unmet Needs this Project Addresses
The Grove in Frontenac is planned as a person-centered model of care. Person-centered care is a
new concept of care. This is not a typical institutional model, but rather offers a more
homelike environment where residents have a say in their day-to-day lives in a setting that
closely resembles their home. The goal of the design is to transform the old institutional culture
to a new culture of caring designed to treat the whole person: their physical, intellectual,
emotional, social, spiritual, and occupational needs.

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Person-centered care is not just about building design or a homelike environment. While there is
no specific model or set of practices, the owners of The Grove in Frontenac believe that in a true
person-centered environment residents are offered choices and encouraged to make their own
decisions. Closer relations between staff and residents are fostered with the same staff
consistently providing care to the same residents. Staff members are trained and have the
authority to respond on their own to resident needs, increasing personal responsibility, reducing
delays, and flattening management hierarchy. Culture change is an ongoing process of overall
performance improvement. Research has demonstrated that organizations with a personcentered model of care experience higher resident and family satisfaction, higher census, reduced
staff turnover and related expenses, improved clinical outcomes, greater operating cost
efficiencies, and improved survey and inspection results.
The owners of The Grove in Frontenac have conducted substantial market research in
determining the location for this facility. In looking closely at the occupancy data for facilities
within the neighboring zip codes (63141, 63124, 63122, 63105 and 63132), the average
occupancy for the most recent quarter for the licensed ALFs/RCFs in these zip codes is at least
85%. The zip code within which the project would be located (63131) has no ALF beds
currently available. (A 60-bed project was issued a CON in 2012 for the zip code, but it has not
broken ground). This is a desirable area for residents who want to live in a safe community
where they can access services and care, but are still mobile and active. With such high
occupancy rates in the immediate area, these individuals would be forced to look outside of their
neighborhoods and community to obtain the environment they are seeking.

II.12 Utilization Historical and Three-Year Projected

Because this is a new facility, there is no historical utilization data to report. The three-year
projected utilization rates, for the first three full years of operations, are as follows:
08/01/16 07/31/17 15,257 Days 48.6 %
08/01/17 07/31/18 25,842 Days 82.3 %
08/01/18 07/31/19 29,200 Days 93.0 %

II.13 Methods and Assumptions for Projecting Utilization

The Grove Assisted Living, L.L.C. will enter into an agreement with a service provider to
provide management and operational services for The Grove in Frontenac (the Service
Provider). The Service Provider is an experienced St. Louis-based operator of senior living
communities. Through the use of the Service Providers internal data and observations from its
experience in the community, and engaging consultants in the industry, the utilization projections
were developed. These utilization rates are similar to other projects in the St. Louis area of a
similar size and scope of services as this project.

12 of 66

II.14 Consideration of Consumer Needs and Preferences

The knowledge for consumer needs and preferences for this community is continually being
acquired through the experience of The Grove Assisted Living, L.L.C. and the Service Provider.
Through the management of their existing facilities, the Service Provider carefully monitors the
input from its residents and incorporates them into the design and planning of its new
communities.
See Attachment II.14 for the notice of the project, which is scheduled to be published in the
St. Louis Post-Dispatch on April 25, 2014, and April 27, 2014.
II.5

Petitions, Letters of Support, Letters of Opposition

No petitions or letters of opposition have been received. Letters of support are forthcoming and
will be submitted as supplemental documents after the filing of this application.

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Attachment II.3

14 of 66

Attachment II.4-5

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18 of 66

Attachment II.8

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33 of 66

CON 15 Mile Radius (City Map)

Attachment II.10.a

Imperial
Kimmswick

Arnold

1400 S Spoede Road & 1396 S Spoede Road

St. Louis, MO 63131

Parkdale Murphy
High Ridge
Byrnes Mill

Scotsdale

34 of 66

CON 15 Mile Radius

63376

63304

63005

63040
63025

63049

63301
63042

63031

63126

63122

63034
63033

63129

63125

63123

63119

63128

63127

63010
63052

63026

63021 63088

Attachment II.10.b

63138

63111

63135
63137
63303
63044
63134
6314063136
63043
63074
63147
63121
63114
63146
63120
63133
63115
63132
63130
63113 63107
63141
63112
63108 63106 63101
63017
63105
63124
63117 63110 63103
63144
63102
63104
63143
63139
63131
63118
63109
63116
63011

1400 S Spoede Road & 1396 S Spoede Road

St. Louis, MO 63131

63341

63038

63025

63025
63051

35 of 66

Attachment II.10.c

CON 15 Mile Radius

1400 S Spoede Road & 1396 S Spoede Road
St. Louis, MO 63131

36 of 66

Attachment II.10.d
2015 Population Projections
City
T

Zip

City

63010 Arnold
63052 Arnold
63025 Byrnes Mill
63049 Byrnes Mill
63051 Byrnes Mill
63049 High Ridge
63052 Imperial
63052 Kimmswick
63026 Murphy
63049 Murphy
63049 Parkdale
63051 Scotsdale

County

Total Pop.

21,227
Jefferson y
Jefferson21,227
+
Jefferson '
3,402
Jefferson
3,402
3,402
Jefferson
4,323
Jefferson
4,799
Jefferson
113
Jefferson
8,604
Jefferson
8,604
Jefferson T,
196
Jefferson
208
Jefferson

37 of 66

65+ Pop.

3,436
3,436
345
345
345
557
608
31
1,182
1,182
34
20

Attachment II.10.e

2015 Population Projections

Zip Codes
Zip

Total Pop.

County

63005 St LouisCo
63010 Jefferson
63011 St LouisCo
63017 St LouisCo
63021 St LouisCo
63025 St LouisCo
63026 St LouisCo
63031 St LouisCo
63033 St LouisCo
63034 St LouisCo
63038 St LouisCo
63040 St LouisCo
63042 St LouisCo
63043 St LouisCo
63044 St LouisCo
63049 Jefferson
63051 Jefferson
63052 Jefferson
63074 St LouisCo
63088 St LouisCo
63101 St Louis City
63102 St Louis City
63103 St Louis City
63104 St Louis City
63105 St LouisCo
63106 St Louis City
63107 St Louis City
63108 St Louis City
63109 St Louis City
63110 St Louis City
63111 St Louis City
63112 St Louis City
63113 St Louis City
63114 St LouisCo
63115 St Louis City
63116 St Louis City
63117 St LouisCo
63118 St Louis City
63119 St LouisCo
63120 St Louis City
63121 St LouisCo
63122 St LouisCo
63123 St LouisCo
63124 St LouisCo
63125 St LouisCo
63126 St LouisCo
63127 St LouisCo
63128 St LouisCo

65+ Pop.

23,110
42,934
38,931
40,63558,784
13,777
43,596
44,982
42,388
18,401
6,802
12,638
17,396
20,648
11,555
15,706
16,029
24,180
13,748
10,782
1,306
2,198
3,847
19,475
12,389
6,290
10,901
23,020
34,583
20,208
23,924
18,261
11,112
33,765
23,174
55,704
8,370
32,091
32,411
10,805
25,686
34,990
46,951
9,140
29,933
13,696
3,926
28,557

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1,357
5,713
6,109
8,646
5,133
1,311
3,607
7,302
7,896
2,320
518
849
2,447
2,559
2,206
1,511
1,552
2,054
2,506
1,266
348
183
727
1,412
2,130
722
1,211
3,089
5,404
1,707
3,062
2,290
1,746
5,465
3,655
6,282
1,473
2,342
7,187
1,128
3,571
7,763
11,994
2,880
7,005
3,676
1,222
6,802

63129
63130
63131
63132
63133
63134
63135
63136
63137
63138
63139
63140
63141
63143
63144
63146
63147
63301
63303
63304
63341
63376
Total

St LouisCo I
St LouisCo
St LouisCo
St LouisCo
St LouisCo
St LouisCo
St LouisCo
St LouisCo
St LouisCo
St LouisCo
St Louis City
St LouisCo
St LouisCo
St LouisCo
St LouisCo
St LouisCo
St Louis City
St Charles
St Charles
St Charles
St Charles
St Charles

52,838
32,684
15,183
12,101
6,059
10,824
20,209
48,810
20,032
21,498
26,983
646
18,649
9,346
8,056
28,037
15,610
50,909
58,223
59,542
4,867
93,751
1,708,592

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6,804
4,014
3,100
2,171
743
1,486
3,183
5,942
3,735
2,823
3,823
64
4,013
1,028
1,315
5,507
1,650
12,338
8,987
7,394
657
11,046
255,161

POPULATION

Zip In

Zip Pop in

Attachment II.10.f

Zip & Radius

City Pop in

Radius

Pop in Zip &

Total Cities'

Zip & Radius

City Pop in

Zip Pop w

1400 S Spoede Rd and 1396 S Spoede Rd, St. Louis, MO 63131

% of Zip

Project Address:

Zip Pop

& Radius

% City in Zip

1,086

Cities' Pop

4,115

Radius W/O

Radius

2,749

Area in

8.616

6,109

Pop

2,749

W/O Cities'

1,086

Pop in Zip

1,366

Total Cities'

80%

ZIP

60%

8,646

6,109

City Pop in

1,357

100%

in ZIP

2,277

100%

% of City

Project Number:

City Pop

0
6,109

City in Zip

3,436

8,646

Pop in Zip

1,311

5,133

0%

100%

5,133

5,133

80%

1,357

Radius

5,713
0
0

3,436

63005

0
0

100%

63010
6,109

3,436

8,646

Arnold

2
63017

3__63011
4
1,311

5,133

100%

7,106

6,572

3,016

100%

0%

1,182

1,182

2,447

849

259

464

7,106

6,572

4,198

90%

234

557

0%

63021

3,016

90%

90%

464

260

1,182

345

63025

7,302

259

Byrnes Mill

5
591

7,896

20%

849

1,251

100%

591

2,320

50%

2,447

69

100%

50%
0

518

100%

100%

557

1,182
0

849

2,206

2,559

Murphy

2,447

3,607

63026

2,320

1,773

518

2,559

0
20%

591

63034
849

100%

2,206

7,896

63038
2,447

2,559

100%

7,302

10
63040

2,206

63033

11
63042

63031

12
2,559

13
63043
2,206

14
63044
345

50%

100%

1,266

2,506

142

2,007

15
Byrnes Mill
557

34

1,182

Murphy

0%

34

100%
276

0%

80%

100%

1,256

34

Byrnes Mill

Parkdale

296

High Ridge

0%

1,511

1,552

63049

63051

16

17

20

100%

0%

3451
201

1,266

2,506

Scotsdale

100%

100%

0%

142

1,266

2,506

10%

0%

0
0

1,415

3,436

0%

0%
0

639

Arnold

31

608

2,054

100%

100%

1,266

2,506

63052

31

608

63088

63074 I

18
Imperial
19

29

_28

27

26

25

24

23

22

21

63111

63110

63109

63108

63107

63106

63105

63104

63103

63102

63101

3,062

1,707

5,404

3,089

1,211

722

2,130

1,412

727

183

348

3,062

1,707

5,404

3,089

1,211

722

2,130

1,412

727

183

348

100%

100%

100%

100%

100%

100%

100%

100%

100%

100%

100%

3,062

1,707

5,404

3,089

1,211

722

2,130

1,412

727

183

348

1,707

5,404

3,089

1,211

722

2,130

1,412

727

183

348

Kimmswick
20

30

3,062

31

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38

37

36

35

34

33

32

63118

63117

63116

63115

63114

63113

63112

2,342

1,473

6,282

3,655

5,465

1,746

2,290

2,342

1,473

6,282

3,655

5,465

1,746

2,290

100%

100%

100%

100%

100%

100%

100%

2,342

1,473

6,282

3,655

5,465

1,746

2,290

1,128

7 , 187

2,342

1,473

6,282

3,655

5,465

1,746

2,290

7,763

3,571

0
0

2,880

11,994

7,005

1,128
7,763

3,571

7,187

100%

100%

11,994

100%

7,763

3,571
100%

7,005

2,880

1,222

3,676

100%

0
11,994

100%

100%

6,802

1,128

0
0

7,005

2,880

5,443

7,187

3,571

3,676

4,014

7,763
0
0

100%

1,222

11,994
0

0
3,676

100%

6,802

63122

63121

2,880
0

1,222

100%

5,443

42

7,005
0
0

6,802

80%

1,128

43 L63123

41

63125

63124
3,676
0
0

6,804

7,187

45

44
63126
1,222
0
0

63120 1

46
63127
6,802
0

63119

47
63128
6,804

40

48
63129

39

49

3,100

743

2,171

0
0

1,486

0
0

0
2,171

3,100
743

4,014
100%

1.486

100%
100%

100%
2,171

100%

5,942

3,183

3,100
743

4,014
0

1,486

5,942

3,183

2,171
0

100%

100%

743

5,942

3,183

3,100

52 1 63132
1,486

4,014

53 1 63133

63131

54 I 63134
5,942

3,183

63130

63136

60

59

58

57

63141

63140

63139

63138

63137

4,013

64

3,823

2,823

3,735

4,013

64

3,823

2,823

3,735

100%

100%

100%

10%

100%

1,315

1,028

4,013

64

3,823

282

3.735

1,315

1,028

4,013

64

3,823

282

3,735

61

100%

100%

1,650

5,507

1,028

7,403

1,315

5,507

100%

1,650

5,507

100%

8,987

1,650

1,315

1,028
5,507

63144
63146
1,650

8,987

7,403

63143

64
63147

60%

63
65

100%

66

5,915

8,987

3,314

12,338

227,329

5,915

80%

66

5,704

7,394

10%

657

5,704

8,987

3,314

12,338
7,394

221,626

63301
63304
657

30%

63303

68
63341

11,046

67
69

248,948

l'

6,2131

11,046

66

62

56

55

63135

50

6,213

51

11,521

63376
255,161

70

DF 4/22/14

41 of 66

Attachment II.14
On 4/23/14 4:40 PM, "Kim Racer" <KRacer@askbrinkmann.com> wrote:
>The ad will run this Friday and Sunday. Attached is a copy of the ad.
>On 4/23/14 4:18 PM, "Tanya Lemons" <TLemons@post-dispatch.com> wrote:
>>Thank you for placing your ad in the St. Louis Post-Dispatch .
>>Date
04/23/14
>>Publication
A
>>Account Number 70760970
>>Ad Number
1890731
>>Total Ad Cost
$450.92 Runs Fri 4/25/14 & Sun 4/27/14
>>
>>$142.46 additional will be charged to the credit card supplied for
>>payment.

42 of 66

DIVIDER III

43 of 66

III.1

ICF/SNF Population-Based Need Methodology

Not applicable.

III.2

RCF/ALF Population-Based Need Methodology

A surplus of 55 RCF/ALF beds in the 15-mile radius has been calculated in accordance with
Missouri regulations, as follows.
1.

The total projected 2015 65+ population in the 15-mile radius is calculated to be 227,329.

2.
Applying the regulatory formula of 25 Residential Care Facility/Assisted Living Facility
(RCF/ALF) beds per 1,000 to the 227,329 results in a total bed need in the radius of 5,684.
3.
The total number of licensed and CON-approved RCF/ALF beds calculated to be in the
radius is 5,739. See Attachment III.2 for the supporting documentation for this calculation.

III.3

LTCH Population-Based Need Methodology

Not applicable.

III.4

Alternate Need Methodology

The applicant would like the Committee to consider the follow factors, which demonstrate that
the actual need is significantly greater than what is shown by the regulatory formula.
(A) The Grove in Frontenac is expected to attract residents from a relatively small area
located predominately within a six zip code area, making a 15-mile radius
inappropriate.
The Grove in Frontenac is highly unlikely to attract residents from St. Louis City, St. Charles or
Jefferson Counties. The 15-mile, population-based need calculation is unrealistic for this type of
a project, because of the needs and preferences of prospective residents and because of
geographic and travel issues.
The generally-active senior citizen seeking care in a facility such as The Grove typically desires
to stay in and around his or her community. Connections to and ties with neighborhoods in the
St. Louis area tend to be long-lasting and are important to continued well-being of residents who
will be seeking care and assistance at The Grove. Remaining close to their communities allows
family, friends and parishioners to participate in residents daily lives, which improves their
quality of life and hopefully delays the need for a higher acuity level of service.

44 of 66

Geographical and traffic constraints are likely to play a significant role in how far individuals are
likely to look for ALFs for themselves or family members. Residents of St. Charles County are
unlikely to look for an ALF that requires crossing the Missouri River into St. Louis County, and
vice versa. Residents of south St. Louis County and Jefferson County are unlikely to be
interested in an ALF in central St. Louis County, and likewise, residents of central St. Louis
County are unlikely to seek an ALF in south St. Louis County or Jefferson County.
Taking the geographical and traffic boundaries into consideration, we believe that The Groves
residents are likely to come predominantly from the following zip code areas: 63131
(Frontenac/Town & Country), 63141 (Creve Coeur), 63132 (Olivette), 63124 (Ladue), 63122
(Kirkwood), and 63105 (Clayton). The number of ALF/RCF beds for just those six zip codes,
when compared to the population-based bed need for the same areas, demonstrates an unmet
need for at least 99 ALF beds.
That unmet need calculation takes into consideration all of the currently CON-approved, but asyet-unbuilt ALFs in that six zip code area, including a 110-bed ALF project approved in 2012,
whose last CON extension expired 11/9/2013. The unmet need calculation also takes into
consideration (i.e., does not exclude) beds that operators have reported as not being available for
occupancy.
See Attachment III.4.A for detailed information on this calculation.
(B) At least 1,387 Beds Located in Facilities that are Licensed by the Department of
Mental Health Should be Excluded from 15-Mile Radius Calculation.
If the entire 15-mile radius were to be included in the need calculation for this project, the
calculation should exclude ALF/RCF beds located in facilities that are licensed by the Missouri
Department of Mental Health (DMH). These facilities deliver necessary mental health services,
but are not typically well-suited for the general aging population seeking person-centered
assisted living care. Facilities licensed by the DMH often involve locked units or other security
features that run contrary to the design and desires of person-centered assisted living facilities
such as The Grove.
Approximately 1,387 beds within the 15-mile radius of The Grove are either licensed by the
DMH or are located in facilities that contain beds that are licensed by the DMH. These beds
should be excluded from the bed count for the 15-mile radius, making the fully-adjusted bed
count in the radius of 4,352, which results in an unmet need for 1,332 ALF beds.
See Attachment III.4.B for a list of facilities in the 15-mile service area with beds licensed by
the Department of Mental Health.
(C) At Least 215 Beds Identified as Not Available for Occupancy Should be Excluded
from 15-Mile Radius Calculation.
ALF and RCF operators are required by Missouri law to report their occupancy levels quarterly,
and to report how many of their beds are unavailable, i.e., not available for immediate
occupancy. Even though the beds are licensed and included in the 15-mile bed count inventory,

45 of 66

they are actually unavailable per the operators report. Frequently, that is because rooms have
been converted from 2-bed rooms to private rooms, but they may also have been converted from
resident use to other purposes, such as offices or storage, or be unavailable because of
remodeling or repairs. Practically speaking, this means that the number of licensed beds that are
actually available for potential residents in the radius is less than the number of licensed beds
reported.
There are currently approximately 430 of the licensed ALF/RCF beds in the 15-mile radius that
are not available pursuant to the most recent occupancy data. (That does not count unavailable
beds in DMH-licensed facilities that the applicant has already recommended be excluded from
the calculation, under Section III.4.B. above.) While the applicant recognizes that some of these
rooms could quickly become available (e.g., converted to semiprivate rooms by the facilities),
the reality is that many of these beds will never be available and, therefore, skew the statistical
bed need calculation.
The applicant proposes excluding half of such beds, as a rough estimate of the number of beds
that are unlikely to ever be available for residents. Consequently, 215 beds should be excluded
from the bed count in the 15-mile radius, because these beds, although identified as licensed
beds, are not considered available for occupancy. Combined with the adjustment described
above in Section III.4.B., the fully adjusted bed count in the radius would be 4,137, which results
in an unmet need for 1,547 ALF beds.
See Attachment III.4.C for a list of facilities with licensed beds that were reported as not being
available on the 2013 Fourth Quarter Occupancy Report.

III.5

Justification for AIDS-Specific Facility

Not Applicable.

III.6

Notice of Noncompliance for Existing Facility

Not Applicable.

46 of 66

47 of 66

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52 of 66

53 of 66

Attachment III.4.A
Frontenac Alternative Bed Need Methodology
Predominant Service Area 6 Zip Codes

Zip Code - City

65+ Pop.
Projection

ALF Bed
Need

Licensed
and CONApproved
ALF Beds

Unmet
ALF Bed
Need

63131
Frontenac + Town &
Country

3,100

78

60

18

63141
Creve Coeur

4,013

101

206

<105>

63132
Olivette

2,171

55

55

63124
Ladue

2,880

72

156

<84>

63122
Kirkwood

7,763

194

33

161

63105
Clayton

2,130

54

54

554

<455>

99

TOTAL

54 of 66

Zip Codes
St. Louis County, Missouri
Zip Codes

Jefferson County

GIS Service Center

veivilmes

Prepared by St Louis County

GIS Service Center
September 2013

55 of 66

Attachment III.4.B
FACILITIES IN THE 15-MILE SERVICE AREA
WITH BEDS LICENSED BY
THE DEPARTMENT OF MENTAL HEALTH
Name

Address

Bed
Capacity

Jefferson County
Cori Manor Healthcare & Rehabilitation Center

560 Corisande Hills Road

Fenton, MO 63026

12

St. Charles County

Harvester Residential Care

35 Lillian Drive
St. Charles, MO 63304

38

Sunshine Home Care St. Charles

618 Hemsath Road

St. Charles, MO 63303

27

Applegate Retirement Home

1204 Telegraph Road

St. Louis, MLO 63125

38

Boarding Inn, The

9444 Midland Blvd.

Overland, MO 63114

40

Converse Home

17025 Old Jamestown Rd.

Florissant, MO 63034

12

Dunn-Dunn House

2133 Jannette Drive

St. Louis, MO 63136

10

Jane Howell Stupp Apartments

2443 Prouhet Avenue

Overland, MO 63114

30

Lutheran Senior Services at Richmond Terrace

1633 Laclede Station Rd.

St. Louis, MO 63117

99

Marymount Manor

313 Augustine Road

Eureka, MO 63025

100

Oasis-Pennsylvania RCF

1004 Pennsylvania Ave.

University City, MO 63130

45

St. Louis County

56 of 66

Attachment III.4.B (contd)

Oasis West

1916 New Jamestown Road

St. Louis, MO 63138

Sabbath Manor

3715 Saint Anns Lane

Normandy, MO 63121

64

Sienna House, Inc.

1322 Leroy Avenue

St. Louis, MO 63133

16

Sylvan House

30 Sherman Road
St. Louis, MO 63125

40

Akins Health Care, Inc.

4432 West Belle Pl.

St. Louis, MO 63108

20

Allways Kare Residential Facility, Inc.

5076 Waterman
St. Louis, MO 63112

20

Amanda Luckett Murphy Hopewell RCF

5117 Waterman Blvd.

St. Louis, MO 63108

12

Benedict Joseph Labre Center

3863 Cleveland
St. Louis, MO 63110

15

Carondelet Retirement Manor, Inc.

6811 Michigan
St. Louis, MO 63111

33

Central Residence, The

5143 Waterman Blvd.

St. Louis, MO 63108

41

Cooper House

4385 Maryland Avenue

St. Louis, MO 63108

36

Holly Hills Retirement Home

6421 Minnesota
St. Louis, MO 63111

15

Lindell Manor

4336 Lindell Blvd.

St. Louis, MO 63108

24

Loving Care (a/k/a Kasey Paige Assisted

Living)

3715 Jamieson Ave.

St. Louis, MO 63109

111

Mary Ryder Home

4361 Olive Street

St. Louis, MO 63108

80

St. Louis City

57 of 66

Attachment III.4.B (contd)

Ms Bs Blessings

4739 Cote Brilliante Avenue

St. Louis, MO 63113

Oasis Residential Facility

3508 Prairie Avenue

St. Louis, MO 63107

20

Provision of Promise

4528 North Market St.

St. Louis, MO 63113

20

Rosati Group Home

4218 North Grand Blvd.

St. Louis, MO 63107

16

Saddler Residential Care Facility II

730 Hodiamont Ave.

St. Louis, MO 63112

20

Silver Spur

3300 Texas Avenue

St. Louis, MO 63118

34

Spring Manor

3610 Palm Street

St. Louis, MO 63107

94

St. Elizabeth Hall

325 North Newstead Ave.

St. Louis, MO 63108

50

Union Manor Residential Care Facility

2711 North Union Blvd.

St. Louis, MO 63113

50

Wardship Residential Care Facility

3409 Missouri Avenue

St. Louis, MO 63118

30

West Pine Group Home

4232 West Pine Blvd.

St. Louis, MO 63108

12

Wilbar Boarding Home

4337 Maryland Ave.

St. Louis, MO 63108

49

TOTAL

1,387

58 of 66

Attachment III.4.C
FACILITIES IN THE 15-MILE SERVICE AREA WITH BEDS
THAT ARE NOT AVAILABLE ACCORDING TO Q4 2013 OCCUPANCY DATA
# Licensed
ALF/RCF Beds

# Licensed Beds
Reported as
Unavailable

Autumn View Gardens at Schuetz Road

100

10

Brentmoor Retirement Community

36

16

Brooking Park

100

27

105+Cape Albeon

100

23

Dolan Residential Care Centers Frontier Manor

10

Fountain View at Friendship Village Sunset Hills

78

12

Ivy Terrace at Gambrill Gardens III

32

11

Laclede Commons

242

108

Lutheran Senior Services at Meramec Bluffs

100

21

Mason Manor

12

McKnight Place

120

75

Schuetz Manor

10

Solana

90

Tesson Heights

72

20

Name
St. Louis County

St. Louis City

Newstead Place

Facilities are required to include information about the number of their licensed beds not
actually available for occupancy in quarterly occupancy reports submitted to the Department
of Health and Senior Services. This information is compiled from those reports.

59 of 66

Attachment III.4.C (contd)

Provision Living at St. Louis Hills

60 of 66

210

105

TOTAL # OF
UNAVAILABLE
BEDS:

430

DIVIDER IV

61 of 66

IV.1

Reasonableness of Cost Per Square Foot

The current RS Means Construction Cost Data for the St. Louis area reports median cost per
square foot as $155.68 and 75th percentile cost per square foot as $181.46.
See Attachment IV.1.
The cost per square foot for this project is $200, which is approximately 10% higher than the
current 75th percentile cost per square foot. This is a reasonable cost per square foot for this
project in light of the amenities and specialty services the facility intends to offer.
IV.2

Documentation of the Availability of Sufficient Financing

See Attachment IV.2.

IV.3

Service-Specific Revenues and Expenses

See Attachment IV.3.

IV.4

Derivation of Patient Charges

The rates for The Grove in Frontenac are based on market research and the prior experience of
The Grove Assisted Living, L.L.C. and the Service Provider with similar communities. Rates
were established based on creating the best value for residents.

IV.5

Responsiveness to the Needs of the Medically Indigent

The Grove in Frontenac will assist residents in obtaining any state, federal, or other
governmental support available for those health care services that may be provided within an
Assisted Living Facility.

IV.6

Admissions for Medicaid Eligible Individuals for New SNF/ICF

Not Applicable.

62 of 66

IV.7

Admissions for Medicaid Eligible Individuals for Existing SNF/ICF

Not Applicable.

63 of 66

Attachment IV.1

RS Means Cost Data

RS Means Cost Data Percentile Limits
Total New Construction Project Costs*
Source: 2014 RS Means Building Construction Cost Data
Type of Facility

Percentile

St. Louis
Area

Kansas City
Area

MissouriOther

National

3/4
Median

360.85
260.84

363.30
262.61

338.10
244.40

350.00
253.00

3/4
Median

198.98
159.81

200.33
160.89

186.44
149.73

193.00
155.00

Residential Care/Assisted Living Facility

3/4
Cost Per Sq. Ft.
Median

181.46
155.68

182.69
156.74

170.02
145.87

176.00
151.00

Hospital
Cost Per Sq. Ft.

Nursing Home
Cost Per Sq. Ft.

* Renovation costs should not exceed 70% of total new construction project costs.
MO 580-1866

64 of 66

Attachment IV.2

April 23, 2014

Karla Houchins
Program Coordinator
Certificate of Need
Department of Health and Senior Services
3418 Knipp Drive
PO Box 570
Jefferson City, MO 65102
Dear Ms. Houchins:
Pulaski Bank is pleased to provide a reference for your use regarding The Grove Assisted
Living, LLC. Based on the entitys current relationship with the Bank, I can confirm that
they have the financial capability to perform on The Grove in Frontenac project.
The Borrower has requested a loan amount of $18,870,095.00 and has cash equity of
$4,717,524.00 to satisfy the total project cost of $23,587,619.00. Full loan commitment
will be issued upon the Banks receipt of written verification of certain facts stated.
Please feel free to contact me if I can be of service to you in any manner.
Best regards,

Brian Bjrkman
President Commercial Lending

65 of 66

Attachment IV.3
Certificate of Need Program

3,700,738
1,174,100

6,382,974
55,816

7,504,400

$4,874,838

$6,438,790

$7,577,758

73,358

SERVICE-SPECIFIC REVENUES AND EXPENSES

2,380,191
718,233
425,929
651,420

2,552,277
770,161
456,723
698,518

2,898,964
874,775
518,762
793,401

$4,175,773

$4,477,679

$5,085,902

24,600
$880,261

41,000
$888,647

82,000

$911,594

$5,056,034

$5,366,326

$5,997,496

-$181,196

$1,072,464

$1,580,262

Historical Financial Data for Latest Three Years plus

2017-18
2018-19
2016-17
Projections Through Three Years Beyond Project Completion
(Use an individual form for each affected service with a
sufficient number of copies of this form to cover entire period,
and fill in the years in the appropriate blanks.)

15,257

_______
$243
$3,700,738
0

Amount of Utilization:*

25,842

Year
_______
$247

$6,382,974

29,200

$257

_______

$7,504,400

Revenue:
Average Charge**
Gross Revenue
Revenue Deductions
Operating Revenue
Other Revenue
TOTAL REVENUE

Expenses:
Direct Expense
Salaries
Fees
Supplies
Other
TOTAL DIRECT
Indirect Expense
Depreciation
Interest***
Overhead****
TOTAL INDIRECT
TOTAL EXPENSE

NET INCOME (LOSS):

* Utilization will be measured in patient days for licensed beds, procedures for equipment,
or other appropriate units of measure specific to the service affected.
** Indicate how the average charge/procedure was calculated.
*** Only on long term debt, not construction.
**** Indicate how overhead was calculated.
MO 580-1865 (08/06)

66 of 66