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b. Provision for Indigent Patients
Petitioner concedes that as of December 31, 1993, Medi-Cal
patients accounted for only 0.8 percent of total procedures
performed at the Surgery Center. Petitioner argues that the type
of services which the Service Center offers is not the type of
services typically sought by low-income individuals. Petitioner
notes that Redlands Hospital has negotiated certain provider
agreements that designate the Surgery Center as a subcontractor
to provide outpatient services for Medi-Cal patients, and that
Redlands Hospital has caused the Surgery Center to increase its
number of managed care contracts. Petitioner suggests that these
efforts demonstrate petitioner’s influence over the operations of
the Surgery Center and evidence petitioner's charitable purposes.
We do not find petitioner’s arguments convincing. The facts
remain that the Surgery Center provides no free care to indigents
and only negligible coverage for Medi-Cal patients. That low-
income individuals may not typically seek the types of services
the Surgery Center offers may partially explain the virtual
absence of relief it provides for such individuals. But it
provides no independent basis for establishing petitioner’s
charitable purposes in its involvement with the Surgery Center.
Moreover, the activities of Redlands Hospital in effecting some
negligible degree of Medi-Cal coverage at the Surgery Center and
in increasing the number of managed care contracts do not provide
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