Read full report by the Attorney General’s Charitable Trust Unit’s investigation of North Country Healthcare: https://indepthnh.org/wp-content/uploads/2026/05/Charitable.pdf
By PAULA TRACY, InDepthNH.org
LANCASTER – The North Country Healthcare’s governing board and management breached its fiduciary duties by failing to follow the appropriate bylaw process for terminating former Weeks Medical Center Affiliate President Mike Lee and by failing to recruit and appoint a full-time, permanent replacement, according to a report from the Attorney General’s Charitable Trust Unit’s investigation.
The Charitable Trust Unit “did not find legal violations as to the other issues reviewed,” according to the report that was made public on Thursday.
Some of the issues investigated were first raised by North Country people who were upset over the termination of a local doctor, concerns about a potential conflict of interest and executive salaries. See story here: https://indepthnh.org/2025/09/08/north-country-healthcare-patients-workers-scared-by-outsourcing-possible-layoffs/
The nonprofit North Country Healthcare operates Upper Connecticut Valley Hospital in Colebrook, Weeks Memorial Hospital in Lancaster, Androscoggin Valley Hospital in Berlin and North Country Home Health and Hospice and is the region’s largest employer.
In November 2025, the Charitable Trusts Unit (CTU) told North Country Healthcare (NCH) that it was conducting a review after former patients of Dr. Elizabeth Cooley and others complained publicly to their elected representatives and the media. https://indepthnh.org/2025/11/12/ag-certain-issues-warrant-further-review-of-north-country-healthcare/
The Charitable Trust Unit examined the accuracy of information North Country Healthcare provided regarding its notice to patients about Dr. Cooley’s termination and their recruitment efforts for primary care healthcare providers, the report said.
“(I)t is generally beyond CTU’s oversight role to second-guess a charity’s decision to terminate an employee for personnel reasons. Without discussing the factual reasons underlying NCH’s decision to terminate its relationship with Dr. Cooley, NCH provided CTU with sufficient information to conclude the process was not contrary to law. While Dr. Cooley established deep roots with her patients, causing many to feel anxiety and concern about being able to transition to comparable care, NCH exercised reasonable care in its notice to patients of the transition and transfer of care,” the report said.
The Charitable Trust Unit also examined NCH’s compliance with governing documents relative to proposed changes to the composition of affiliated hospital boards; their contracting process for revenue cycle management services; the substantial turnover on the Weeks Medical Center Board; (WMC) and the NCH board’s process in determining compensation for executive officers.
The probe found: “NCH’s board did not violate its fiduciary duties in relation to executive compensation.”
The report also said concerns about the selection of Hartzler Healthcare as a vendor didn’t constitute a violation of duty.
“NCH’s board did not violate its fiduciary duties with respect to the selection of Hartzler Healthcare as a third-party vendor for revenue cycle functions,” the report said.
The report said North Country Healthcare has agreed to abide by a series of Charitable Trust Unit imposed requirements. They include the appointment of an Independent Board Governance Consultant to be chosen by the New Hampshire Department of Justice.
“The Independent Consultant will oversee, among other duties, NCH’s recruitment of new Weeks Medical Center board members, public listening sessions over the next year to be held quarterly by NCH, and NCH’s recruitment of a WMC Affiliate President. The Independent Consultant will provide DOJ with quarterly reports that will be posted on DOJ’s website,” the report said.
Attorney General John Formella said in a news release: “Ongoing communication with stakeholders within our nonprofit healthcare systems, together with full compliance with charitable trust laws, is critical to maintaining public trust that decisions are being made in the best interests of the communities served.
“North Country Healthcare must work diligently with the Independent Board Consultant to prove to the North Country community that NCH is committed to improving relations with the affiliate boards and the community. We appreciate NCH’s willingness to come to the table, and we stand ready to ensure compliance with the terms of this agreement.”
The Charitable Trust Unit conducted more than 20 stakeholder interviews, including past and present board members and executive leadership. In October 2025, CTU met with a group of approximately eight members of the concerned patient group, Sen. David Rochefort, R-Littleton and NCH executives at WMC in Lancaster and, in January and February of 2025, CTU attended two listening sessions conducted by NCH in Berlin and Lancaster.
CTU also issued requests for information to which NCH provided written responses in a timely manner and produced over 2,000 pages of responsive documents.
North Country Healthcare will reimburse the Charitable Trust Unit for a portion of its costs and fees associated with this review in the amount of $75,000. The payment shall be deposited in CTU’s nonlapsing account for education and training, the report said.
Tom Mee, CEO of North Country Healthcare issued a statement after the report was released Thursday saying “rural healthcare is about neighbors, families, longtime relationships, and ensuring that care will be here when people need it.”
He said in several important areas, “CTU found that NCH’s actions were reasonable and appropriate. The report found that NCH took sufficient steps to notify patients and support transfer of care during a provider transition. It also recognized something we experience every day: recruiting primary care providers in rural New Hampshire is difficult. Even with those challenges, CTU found that NCH is taking reasonable steps to recruit and strengthen our primary care workforce.”
“The report also found no breach of fiduciary duty related to the selection of NCH’s external revenue cycle partner. CTU found that the contract did not create a conflict of interest, did not involve self-dealing, and that no NCH board members or executives had a direct or indirect financial interest in the vendor. CTU also found no breach of fiduciary duty related to executive compensation review, while noting the importance of continued attention to how compensation review processes are applied.
“…The report identifies areas where NCH has follow-up work to do. CTU found a breach of duty related to bylaw adherence with regard to the removal process of an affiliate president and by not actively recruiting and installing a full-time, permanent affiliate president. CTU further concluded that these changes led to challenges in the governance process at the affiliate. As a result of CTU’s findings, CTU and NCH have agreed upon a set of conditions that NCH will implement. We respect the CTU’s review process and accept the CTU’s recent findings,” Mee said.
State Sen. David Rochefort, R-Littleton, whose district includes all of Coos County, said the report was “thorough” and the Charitable Trust Unit investigated the citizens’ concerns to the extent of their authority and “found some pretty big issues” which need to be addressed.
Rochefort said someone lost their job improperly and the rules of board governance were exposed by the lengthy probe.
What also has come from the report is “reassurance” that North Country Healthcare is financially healthy and “they will be able to provide care well into the future,” for these small hospitals, he said.
“I think we all can learn and grow from this,” Rochefort said and from what he has been hearing from hospital executives is that they “want to strengthen their relationship with the communities they serve.”
He also noted that a good outcome from the CTU study is that there will be an independent consultant who will provide him quarterly updates and will be paid for by the hospital.
Rochefort said if there are tools that are needed from the legislature he would stand willing to support such measures.
“I’ll be watching it closely,” he said Thursday afternoon.