Community Care Coalition


In March 2021, one of the largest healthcare systems in Massachusetts filed three determination of need (DoN) proposals, totaling $2.4 billion, with the Department of Public Health (DPH). One of the applications sought approval to build three ambulatory surgery centers (ASCs) in the communities of Woburn, Westwood, and Westborough.

After the filing, several healthcare providers engaged IMG to draw attention to stakeholder concerns about the expansion. With the system considered the largest and most expensive healthcare provider in the state, IMG was tasked with drawing attention to how an expansion of service area would impact local healthcare providers, as well as statewide healthcare affordability, access, and equity.

Designed to protect local physicians, providers and health systems, this campaign was critical to ensuring the financial viability and availability of community care for patients, especially those with barriers to accessing care.


IMG publicly launched the Coalition to Protect Community Care and swiftly undertook a substantial outreach effort to influential nonprofits, businesses, unions, and chambers of commerce. Addressing the concerns of each group, IMG held numerous presentations about the expansion and ways to get involved.

To generate visibility, IMG leveraged the individual and collective influence of Coalition members by helping them articulate their concerns through letters to the editor and op-eds. Each piece conveyed the unique concerns of the Coalition, leveraging the insights of chambers of commerce, former policymakers, nurses, and more.

Momentum gained at the grassroots level was supplemented by targeted engagement of policymakers at the state level. Understanding that the health system’s proposal could be denied through a lack of support from the DPH, which considers insight from the Health Policy Commission and Attorney General’s Office (AGO), and through legislation, IMG undertook two important initiatives. IMG facilitated a meeting for members of the AGO’s health bureau with seven Coalition members to discuss how the proposal would shape the healthcare access, costs, and experiences of each group’s membership base. The Coalition also launched a letter platform, allowing constituents to vocalize their support of legislation championed by the Speaker of the House that was designed to strengthen protections for community hospitals against the expansion of higher cost health systems through the DoN process.

Through paying close attention to the regulatory process, the Coalition provided timely written and oral comments and, in turn, was included in coverage throughout the review process.


Through targeted outreach, the Coalition secured the endorsement of 26 organizations and landed over 50 pieces of media coverage throughout the campaign.

The attention generated by the Coalition around the health system’s DoN applications also informed the stance of healthcare policymakers and regulators, with the AGO publishing a report on the possible impacts of the expansion project and the Coalition-backed bill H4253 passing in the House with only one vote of dissent.

In a historic outcome, the health system that was seeking the expansion decided to withdraw its DoN application for all three proposed ASC sites on April 1, 2022, after DPH concluded it would not recommend the DoN application for approval. This outcome would not have been possible without the widespread public awareness generated by the Coalition.

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