September 22, 2010

David Spackman, Esq.

Director, Division of Public Charities
Office of the Attorney General
One Ashburton Place
Boston, MA 02108

Dear Mr. Spackman,

On behalf of working men and women throughout the Commonwealth of Massachusetts, we write
to express our continued and unified support for the acquisition of Caritas Christi Healthcare by
Steward Healthcare System.

As labor unions and health care consumers we are concerned about the rising costs of healthcare
and understand that community hospitals in Massachusetts must have the necessary resources to
provide high quality, lower cost care for patients across the state. We are committed to working to
control healthcare costs and to ensure that all Massachusetts residents, particularly the most
vulnerable, have access to a choice of high quality, affordable care. As you know, five out of six of
Caritas’ hospitals are disproportionate share hospitals, caring for the poorest patients in lower cost
community settings. We support this merger to ensure community hospitals, like Caritas Christi
Healthcare, are vibrant, viable healthcare institutions that can help to address the rising cost of
healthcare.

We support the Caritas acquisition not only as a way to provide innovative financing to improve
and expand affordable healthcare in communities across Massachusetts, but also because this
financing will grow and protect jobs. The communities Caritas Christi serves will benefit from this
acquisition, as Steward Health Care System will immediately invest $116 million to complete
important renovations and upgrades at each of the system's six hospitals; community members will
continue to have access to the same health care providers; and communities will continue to
benefit from jobs in the healthcare industry. In these recessionary times, an employer who is able
to expand its workforce, and who has committed to good jobs with good benefits is an employer
that should be applauded as well as supported.

We are also aware that you are in receipt of a letter from concerned competitors of the Caritas
Christi Healthcare System and their allies. Much of what the coalition is asking for is already
covered by existing law (for example, anti-competitive behavior and improper physician
inducement are already illegal) or would be an unfair burden placed on Caritas when other
hospitals have no such constraints. One proposal asks for restrictions on Caritas’ participation in
limited network insurance plans, a proposal that runs counter to the recent small business
legislation enacted in Massachusetts this summer. Furthermore, it is through an existing Caritas
limited network that many of our workers receive high value low cost health care coverage. We
were therefore concerned to read about these proposals made by Caritas competitors Lawrence
General Hospital, Signature Brockton and Southcoast (“the Healthcare Access Coalition”), which
seems to be trying to simply slow down any merger as a way to preserve their market share and to
disadvantage Caritas.
We believe that regulatory process around the Caritas merger has been thorough, transparent,
inclusive of all voices, and conducted at a very reasonable pace. We appreciate the ongoing work
by the Attorney General’s office and the Department of Public Health to ensure opportunity for all
community stakeholders to weigh in, and a vast and vocal majority of those stakeholders have both
supported the merger and called for a timely approval of its current terms.

We, along with the overwhelming majority of community members, advocates, and elected
officials think this transaction meets the Attorney General’s standards to ensure that it is in the
public interest and in compliance with applicable non-profit and charities law. We believe the
transaction should be approved without unnecessary delay. Failure to approve this transaction
would jeopardize not only the Caritas Christi Healthcare System, but also healthcare and
construction jobs.

Robert Haynes Veronica Turner

President Executive Vice President
Massachusetts AFL-CIO 1199SEIU

Allen R. McWade Michael P. Monahan

Business Manager Business Manager
IUOE Local 877 IBEW Local 103
President of the Area Trades Council

Mark Erlich Rich Rogers

Executive Secretary-Treasurer President
New England Regional Council of Carpenters Greater Boston Labor Council

Julie Pinkham
Sean M. O'Brien Executive Director
President, Principal Officer Massachusetts Nurses Association
Teamsters Local 25

Francis X. Callahan, Jr.

President
Massachusetts Building Trades Council