Mass General Brigham defended plans on Thursday to undertake a $2.3 billion expansion, writing to state regulators that concerns about the project’s effects on health care spending were overstated and that a state agency criticizing the projects had overstepped its authority.
In documents filed with the Department of Public Health, the state’s largest health system outlined the case for its expansion, which includes opening ambulatory sites in Westborough, Westwood, and Woburn, and building multi-million dollar additions at Massachusetts General Hospital and Brigham and Women’s Faulkner Hospital.
The Health Policy Commission, which monitors health care spending in the state, fiercely criticized the projects on Tuesday, saying they would raise annual health care spending by between $46 million to $90.1 million and siphon millions of dollars away from often-struggling hospitals serving low-income patients.
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The Department of Public Health will review the commission’s comments as it contemplates whether to approve the expansions. A decision is expected in the next several months.
However, Mass General Brigham executives downplayed those concerns to regulators, writing in public comments that the commission’s concerns were “speculative” and “blind to the current state of the health care system.”
“The Department must be mindful that HPC’s comments are provided in a vacuum and do not balance all of the factors that the Department must review,” said David McCready, president of Brigham and Women’s Faulkner Hospital, in one of three letters submitted to regulators. “Moreover, the HPC conclusions are based on unsubstantiated assumptions designed to inflame the public discourse regarding the proposed project and MGB overall.”
Hospital executives suggested regulators look to an analysis commissioned by Mass General Brigham, which suggested the projects would result in modest savings in state health care spending.
The Health Policy Commission did not immediately respond to a request for comment.
Much of the commission’s criticism has faulted Mass General Brigham for attempting to grow when it is already the largest and the most expensive provider in the state.
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The commission also said that a bigger Mass General Brigham would drain business from other health care providers at an estimated $150 million to $261 million a year. That could destabilize community hospitals that have fewer financial resources and serve more low-income patients.
Some of the criticisms echoed a blistering report issued in November by Attorney General Maura Healey. On Thursday, her office submitted additional comments to the Department of Public Health suggesting that the projects would raise health care spending and would threaten nearby community hospitals.
MGB declined to comment on her letter.
In a three-part response to the Health Policy Commission analysis, Mass General Brigham executives said the agency was overstepping its authority in its review. Executives also criticized the conclusions the commission reached on the expansion and said the commission ignored the real-time constraints the current system was facing.
John Fernandez, president of Mass Eye and Ear and president of Mass General Brigham Integrated Care, said in one letter that denying the projects would limit patient choice.
“If our patients want to continue receiving care from MGB, then the HPC’s view is that they should continue to travel to MGB’s higher cost hospital options,” Fernandez said. “According to the HPC, if MGB patients don’t like the inconvenience, they can use local non-MGB providers. The HPC would remove MGB patients’ choice and direct them to providers that they do not choose to use, which is equivalent to government directed, rationed care.”
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David Brown, president of Massachusetts General Hospital, said in a second letter that the HPC review did not consider the current capacity crisis the hospital was facing, and ignored future projections of increasing volume.
“The HPC’s role is narrow — to contain monetary health care costs,” Brown wrote. “The HPC does not consider the benefits of a project from the access or quality perspectives. But that is, in fact, DPH’s role, and it is critical that the DPH not lose sight of its broader purpose in determining what is needed for the good of public health.”
McCready, the president of the Faulkner, said the commission’s analysis were “designed to reach its predetermined conclusion.” He also said the health system was being held to a higher standard than the state’s process required.
“These standards should not be imposed on the proposed project just because the applicant is MGB,” he said.
Jessica Bartlett can be reached at jessica.bartlett@globe.com. Follow her on Twitter @ByJessBartlett.