Quick Summary: For issuance of a certificate of need to add skilled nursing beds to an existing skilled nursing facility, the state agency should consider the need for such beds only as such need exists within the appropriate "planning area" as defined by state law, according to the Appellate Court of Illinois.

   In this case, the appropriate planning area was the county where the facility was located which was seeking to add additional skilled nursing beds. A challenger located in another county could not contest the actions of the state agency in approving a certificate of need in the county where the applicant was located. The state agency and the court in reviewing the state agency would look only to the state agency’s assessment of need for skilled nursing beds in the county where the applicant was located, and not look at the supply of skilled nursing beds in a larger geographical context, even if the larger area contained redundant beds in contravention of the spirit of state health care planning policy. Springwood Assoc. vs. Health Facilities Planning Board, 646 N.E. 2d 1374 (Ill. App., 1995).