505 FOREST AVE. ● LAGUNA BEACH, CA 92651 ● TEL (949) 497-3311 ● FAX (949) 497-0771
September 21, 2026
The Honorable Rob Bonta
California Attorney General
Post Office Box 944255
Sacramento, CA 94244-2550
RE: Mission Hospital Laguna Beach’s Possible Closure
Dear Attorney General Bonta –
In July of this year, your staff was kind enough to meet with us (as representatives of the City of Laguna Beach) to discuss the possible closure of Mission Hospital Laguna Beach (“Hospital”), the lone acute care hospital in Laguna Beach.1 The Hospital, currently operated by Providence Health, has been part of our community since 1959. We believe that its emergency room services are vital to the health and safety of our 23,000 residents and the tens of thousands of visitors who come to our community and beaches on a busy weekend or summer day. The number of annual visitors to the city exceeds 6 million.
Providence has told us that it intends to close the Hospital effective January 1, 2030, in part because of the “$300M to $350M” in seismic upgrade costs required by State law, as well as Providence’s desire to bring a non-acute care medical center model to our town (i.e., a more modern medical center without in-patient services), one which Providence believes will be more financially sustainable and will offer a broader range of non-emergency medical services than currently provided at the Hospital site.
Our major concern is that Providence’s proposed model leaves the community with no Emergency Department (ED). The closure of the ED presents two distinct adverse impacts. First, the majority of the patients—who currently walk into the ED—will have to travel much greater distances to access emergency care. Second, there will be negative impacts to the operation of the City’s 911/EMS delivery system should the Hospital close.
Since 2023 we have run the local ambulance service through our Fire Department with two ambulances (upstaffed to three ambulances during weekend days between Memorial Day and Labor Day) and 12 employees staffing the operation. With this team, we have averaged over 1,600 transports annually with the vast majority of those patients being taken to Mission Hospital Laguna Beach. If our community’s two or three ambulances, in some cases accompanied by a fire engine, are frequently on the road delivering patients to neighboring communities such as Mission Viejo, Irvine and Newport Beach, then that adversely affects the ability of our first responders to provide care and safety for our residents and visitors.
1 Mission Hospital Laguna Beach is operated as a “second campus” to Mission Hospital, Mission Viejo. The larger hospital is geographically separated from the City of Laguna Beach.
Docusign Envelope ID: 6809BFD9-A030-8C56-8037-E893B9536B3F 505 FOREST AVE. ● LAGUNA BEACH, CA 92651 ● TEL (949) 497-3311 ● FAX (949) 497-0771 Given our strong belief that there will likely be adverse consequences to a closure of the Hospital and the loss of the ED, we have asked, and Providence has agreed, to explore two approaches to maintaining an ED in Laguna Beach. Specifically, Providence and the City have agreed to pursue legislation that would allow for a stand-alone ED at the Hospital site and to evaluate the feasibility of a small, micro-hospital with an ED and a limited number of ICU beds. Providence has made clear that its willingness to study a micro-hospital in no way commits Providence to include such a facility in its future plans.
We appreciate Providence’s willingness to consider a stand-alone ED in its plans (if allowed via new legislation) and to evaluate the feasibility of including a smaller acute care hospital but remain concerned that neither of these options are guaranteed to result in our maintaining an ER. The overwhelming response from our community to Providence’s announcement is that it is essential for the City to find a way to maintain a hospital and an ED in Laguna Beach.
The Attorney General's office was involved a decade ago when Providence proposed a significant realignment of its hospital systems across California. At that time your office commissioned a study by Vizient. The Vizient study is linked here. With respect to emergency services the Vizient study concluded that “it is critical that Mission Hospital and Mission Laguna Beach maintain their emergency services.” At that time, the Attorney General’s office imposed a number of conditions on the merger between Providence and St. Joseph’s including that the ED at the Hospital continue to operate for at least “five years from closing” and that “for a period of five years from the closing (each affected hospital will) continued to be maintained as a licensed general acute care hospital.” 2 We understand that the proposed closure itself would not trigger a review by your office like the one conducted in 2016 as the action does not involve a merger or ownership change. We believe, however, that the Attorney General's office still may have an interest in the possible closure of Mission Hospital Laguna Beach, for a variety of reasons set forth below. Therefore, we offer the following informational comments and requests as follow-ups to our July 23, 2026 meeting with your staff:
First, we had previously filled out a form via your web portal to make a brief appointment with you to ensure that you were aware of the community's concerns regarding the possible closure of the Hospital and the lack of a full-service emergency department in our community after 2030.
We would still appreciate having that brief meeting.
Second, we have met with Orange County’s Emergency Medical Services division (OC EMS) to ask them to consider an updated EMS Impact Study with and without Mission Hospital Laguna Beach in operation. The end result of that meeting was that OC EMS does not intend to do an Impact Study for the regional EMS system until OC EMS is formally notified of the Hospital’s closure. However, this may not happen until six months before January 2030, which seems too late for effective planning. It may be essential that an earlier impact study is done, or encouraged.
We would ask that your office assist in requesting an impact study on the proposed closure of the Hospital.
2 2016 Vizient Study, page 93, as well as June 16, 2016 CA AG conditional consent to change in governance for Providence / St Josephs.
Docusign Envelope ID: 6809BFD9-A030-8C56-8037-E893B9536B3F 505 FOREST AVE. ● LAGUNA BEACH, CA 92651 ● TEL (949) 497-3311 ● FAX (949) 497-0771 Third, following up on your office's 2016 Vizient study of the consolidation of various Providence hospitals across California, we offered to share with your office the current information about the transport of patients to and from the City of Laguna Beach by our Fire Department’s ambulance transport system, which is shown below for the recent 13-month period ending towards the end of August 2026. As you can see, Mission Hospital Laguna Beach is still the primary destination for ambulance transports from our system.
Additional historical and current data for the Mission Hospital Laguna Beach ED is provided in Attachment A to this letter. We believe that this data supports a conclusion that retaining an ED in Laguna Beach is as critical, if not more critical, now than it was in 2016 when your office drew that conclusion.
Fourth, we inquired as to how your office would or could review the disposition of granted / donated funds to Mission Hospital Laguna Beach for the purpose of constructing and operating the ED (press release copy here), assuming that the Attorney General retains supervisory jurisdiction over this charitable asset.3
Fifth, while the Vizient study and related documents show the last of the specific obligations that the Attorney General imposed on Providence expiring in 2026 , a follow-up action in 2024 involving the Attorney General and the Rady Children’s Hospital of San Diego and the Children’s Hospital of Orange County (CHOC) appears to have directed that 24-hour emergency services remain at Mission Hospital Laguna Beach at least through 2034.
More specifically, the 2024 affiliation agreement document provides:
3 Corp. Code, §§ 5914–5917; Gov. Code, § 12598.
Destination Amount % of
Total
Childrens Hospital OC (CHOC) 2 0.1%
Hoag Irvine Medical Center 58 3.2%
Hoag Memorial Hospital 136 7.5%
Kaiser Hospital - Irvine 51 2.8%
Mission Hospital Regional Medical Center 387 21.4%
Mission Hospital - Laguna Beach 1085 59.9%
Saddleback Memorial Medical Center 86 4.7%
UCI Health - Irvine 5 0.3%
UCI Medical Center - Orange 1 0.1%
Total = 1811 100.0%
LB FD Ambulance Transports per Destination
7/1/2025-8/25/26 (13 months)
Docusign Envelope ID: 6809BFD9-A030-8C56-8037-E893B9536B3F 505 FOREST AVE. ● LAGUNA BEACH, CA 92651 ● TEL (949) 497-3311 ● FAX (949) 497-0771 Note: (a) and (b) are deleted from this letter as they apply to Rady and to CHOC.
Our question regarding this point is whether the Rady-CHOC requirement under Section IV (c) 5 is effective to late 2034, as our layperson’s read of it may suggest.
Lastly, as your office reviews other changes in hospital ownership affecting Providence across California, we respectfully ask that you consider how those changes might financially assist Providence in maintaining a hospital (even one of small size) in Laguna Beach. While we are not experts in hospital financing, it seems to us that a partial re-capitalization of the Providence system infrastructure as a result of possible facility sales or transfers elsewhere could support Providence’s fiscal ability to stay in Laguna Beach with an operational 24/7 Emergency Department.
Thank you again for your staff’s attention to our concerns, and we look forward to hearing from you regarding any follow-up items suggested by this letter.
Sincerely,
ALEX ROUNAGHI BOB WHALEN
City Council City Council
Attachments: Attachment A – More Data on the ED and the Attorney General’s Past Input Docusign Envelope ID: 6809BFD9-A030-8C56-8037-E893B9536B3F 505 FOREST AVE. ● LAGUNA BEACH, CA 92651 ● TEL (949) 497-3311 ● FAX (949) 497-0771 cc:
Members of the Laguna Beach City Council
Members of the Hospital Task Force
City Manager Dave Kiff
City Attorney Megan Garibaldi
Mr. Seth Tiegen, Chief Executive, Providence Mission Hospital Docusign Envelope ID: 6809BFD9-A030-8C56-8037-E893B9536B3F 505 FOREST AVE. ● LAGUNA BEACH, CA 92651 ● TEL (949) 497-3311 ● FAX (949) 497-0771 Attachment A
More Data on the ED and the Attorney General’s Past Input Providence has said that a possible replacement for the Mission Hospital Laguna Beach and its ED could be a 24/7 “advanced medical care center,” providing a range of out-patient services but not one authorized to receive emergency transports since the center will not be an acute care facility.
Providence has stated its belief that the vast majority of the patients currently being treated at the ED could be seen and cared for at the advanced medical care center without any adverse impact on health outcomes. We are concerned that this may not be the case based on the data and other information summarized below.
1. Mission Laguna Beach ED Sees Many High and Moderate Complexity Cases.
As evidenced in the table below, Providence’s filing with HCAI for calendar year 2025 shows a high demand for the ED and a large percentage of “high” and “moderate” complexity cases.
There is research concluding that roughly 14 to 27 percent of emergency room visits nationally could be managed at urgent care centers and retail clinics.4 However, these concern the lowestacuity levels of emergency department caseloads; no published study that we are aware of supports treating high-complexity patients in urgent care facilities.
2. Prior Review of Mission Laguna Beach ED by Attorney General Highlights Critical Need for ED
In connection with the 2009 sale of the Hospital, the Attorney General commissioned an independent healthcare impact report from Medical Development Specialists, Inc. Its conclusion was that the emergency department at the Laguna Beach campus “is needed for patient access”; travel times to other emergency departments “could equal 30-40 minutes from remote portions of 4 Weinick, Burns & Mehrotra, Many Emergency Department Visits Could Be Managed at Urgent Care Centers and Retail Clinics, Health Affairs, vol. 29, no. 9 (2010) (estimating that 13.7–27.1% of emergency department visits nationally — the lowest-acuity fraction of ED caseloads — could be managed at urgent care centers and retail clinics).
Docusign Envelope ID: 6809BFD9-A030-8C56-8037-E893B9536B3F 505 FOREST AVE. ● LAGUNA BEACH, CA 92651 ● TEL (949) 497-3311 ● FAX (949) 497-0771 the service area”; “this could pose a safety risk”; and access “would be particularly difficult when summer visitors increase the population.”5 At the time, the Orange County EMS Agency emphasized the same concerns, along with the Hospital’s role in county disaster preparedness.
These findings became the basis for the operating conditions the Attorney General attached to the sale.
In 2016, the Attorney General commissioned another impact statement, this time by Vizient, in connection with the merger between Providence and the St. Joseph Health System, which found both the Mission Viejo and Laguna Beach hospitals “very important” to the service area. With respect to the provision of emergency services the Vizient report stated:
“In addition, the anticipated closure of Saddleback Memorial Medical Center’s San Clemente campus is expected to result in increased emergency department utilization within the service area.
In order to ensure access to emergency services within the service area, it is critical that Mission Hospital and Mission Laguna Beach maintain their emergency services.” These findings resulted in the Attorney General’s condition to the 2016 merger that Providence maintain its emergency-care services at Mission Laguna Beach for a five-year period.6 Twice, on independent review commissioned by the Attorney General, the evidence supported keeping the Mission Hospital Laguna Beach ED open. The data shows that the need for the ED in Laguna Beach has not diminished over time. The year before the 2009 report, the ED recorded 13,142 visits; in 2025 it recorded 14,827 — 13% more — with nearly half classified at the highest complexity level. As set forth below, the ED has seen between 14,800 and 17,600 visits every year for the last decade (Exhibit A).7
5 Medical Development Specialists, Inc., Healthcare Impact Report (Apr. 16, 2009), prepared for the Office of the Attorney General as Exhibit 1 to the Attorney General’s June 9, 2009 conditional consent to the sale of South Coast Medical Center (“SCMC’s emergency department is needed for patient access . . . travel times to other hospitals’ EDs could equal 30-40 minutes from remote portions of the SCMC’s service area and . . . this could pose a safety risk. Access would be particularly difficult when summer visitors increase the population and make traffic patterns much more difficult.”).
6 MDS Consulting (a Vizient, Inc. business), Healthcare Impact Statement: Mission Hospital Regional Medical Center and Mission Hospital Laguna Beach (Mar. 28, 2016), prepared for the Office of the Attorney General (finding both hospitals “very important providers to both the local communities and the service area.”) 7 Providence annual HCAI utilization filings for Mission Hospital Laguna Beach, CY 2012–2025.
Docusign Envelope ID: 6809BFD9-A030-8C56-8037-E893B9536B3F 505 FOREST AVE. ● LAGUNA BEACH, CA 92651 ● TEL (949) 497-3311 ● FAX (949) 497-0771 Exhibit A
As predicted in the Vizient study, when San Clemente’s hospital closed in 2016, its emergency volume shifted to other hospitals. In 2025, the total visits to the emergency room at Mission Hospital were approximately 20% higher than 2016 and the emergency room showed signs of being impacted as it logged 371 hours on ambulance diversion in 2025 — 183 of them in January alone (Exhibit B).8
Exhibit B
8 HCAI utilization filings, Saddleback Memorial Medical Center San Clemente (closed May 31, 2016) and Providence Mission Hospital (Mission Viejo), CY 2012–2025; Orange County EMS Agency 2016 impact evaluation; see Exhibit C.
Docusign Envelope ID: 6809BFD9-A030-8C56-8037-E893B9536B3F 505 FOREST AVE. ● LAGUNA BEACH, CA 92651 ● TEL (949) 497-3311 ● FAX (949) 497-0771
3. A Closure of Mission Laguna Beach ED Will Significantly Increase Travel Times to Emergency Care
Our Fire Department operates three ambulances and averages a five-minute transport to Mission Hospital Laguna Beach; after closure, it’s likely that every emergency becomes a 17-to-35-minute transport (Exhibit C).9 The time-sensitivity is rooted in the ED’s actual caseload: 7,131 visits last year were classified at the highest complexity level on Providence’s own filing — a tier defined in part by threats to life or bodily function — and because 80% of patients arrive at the Mission Hospital Laguna Beach ED by private car rather than ambulance, this location provides the nearest facility to stabilize walk-in patients exhibiting cardiac, stroke, respiratory and other serious medical conditions. For those patients, added minutes to treatment could have significant adverse health effects.10 Research on emergency department closures is direct: residents affected by the closure of a nearby emergency department experience approximately five percent higher odds of inpatient death, with additional mortality documented at the neighboring hospitals that absorb the displaced volume.11
Providence reports that only 2.5% of patients are transferred to Mission Viejo after being received at the Mission Hospital Laguna Beach ED — but that number measures transfers after stabilization at Laguna Beach, and does not analyze the key question of what the medical impact on longer travel times for patients who are not quickly stabilized at Laguna Beach and then transported. 12 Exhibit C
9 Statements of Laguna Beach Fire Chief Niko King (Jan / Feb 2026) (average five-minute transport to Mission Hospital Laguna Beach; approximately 800 hospital transports per year with two City ambulances). 10 Saver, Time Is Brain — Quantified, Stroke (2006) (approximately 1.9 million neurons lost per minute of untreated ischemic stroke); see also Seymour et al., N. Engl. J. Med. (2017) (hourly increase in sepsis mortality with delayed treatment).
11 Liu, Srebotnjak & Hsia, Health Affairs (2014) (approximately 5% higher odds of inpatient mortality among residents affected by an emergency department closure); Shen & Hsia, Health Affairs (2019) (increased mortality at neighboring hospitals absorbing displaced emergency volume); Singer et al., Academic Emergency Medicine (2011) (emergency department boarding beyond 12 hours associated with approximately doubled inpatient mortality). 12 Providence June 8, 2026 materials, supra note 4 (2.5% inter-facility transfer rate).
Docusign Envelope ID: 6809BFD9-A030-8C56-8037-E893B9536B3F 505 FOREST AVE. ● LAGUNA BEACH, CA 92651 ● TEL (949) 497-3311 ● FAX (949) 497-0771 Docusign Envelope ID: 6809BFD9-A030-8C56-8037-E893B9536B3F