The court's opinion notes that its analysis is limited to the facts as they were in 2002, the year the hospital's exemption was challenged, and that state law confines the court's review to whether the administrative decision by the Illinois Revenue Department was clearly wrong. An appeals court sided with the state in 2008.
Illinois Supreme Court Justice Lloyd Karmeier writes in the opinion at one point that if the number of poor, uninsured and underinsured residents in Provena Covenant's community was as insignificant as its charity care program, then there would be little reason for its parent, six-hospital Provena Health, to pursue its charitable mission there. “The only plausible explanation would be that its principal purposes in operating PCMC were, in reality, more temporal than it professes.”
The hospital's charity care, Karmeier writes, “was often illusory” because low-income patients were granted discounts of 25% or 50% off rates that were double the hospital's cost.
Nor was the court persuaded by arguments that the hospital removes a burden from other government agencies. Karmeier writes that none of the taxing bodes that collect revenue from Champaign County property taxes are in the business of providing healthcare, and the hospital's exemption from state and federal taxes was not at issue.
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