Justia Public Benefits Opinion Summaries

After Defendants were charged with Medicaid fraud, the Commonwealth obtained search warrants to obtain and search designated e-mail accounts of Defendants' former billing director. Defendants moved for a protective order, claiming that the attorney-client privilege protected many of the e-mails. A motion judge amended the order to permit the Commonwealth to search the e-mails by using a "taint team," assistant attorneys general not involved in the investigation or prosecution of Defendants. Defendants filed a petition seeking relief from the order. The Supreme Court answered reported questions from the county court by holding (1) the Commonwealth may, by means of an ex parte search warrant, search the post-indictment emails of a criminal defendant; and (2) the "taint team" procedure was permissible under the Massachusetts Constitution. View "Preventive Med. Assocs. v. Commonwealth" on Justia Law

Three corporations, each of which owned a nursing home facility, requested a hearing with the Kansas Department on Aging, challenging new reimbursement rates for each facility, arguing that because the facilities underwent a change of ownership, the rates should be recalculated. The hearing officer rejected the corporations' arguments, finding that, by operation of law for Medicaid reimbursement purposes, there was no change of ownership. The Kansas Health Policy Authority upheld the ruling, and the district court affirmed. The Supreme Court affirmed, holding that the agency orders were valid, did not violate equal protection or due process, and were not vague. View "Village Villa v. Kan. Health Policy Auth." on Justia Law

Applicant Marilyn Clifford appealed the denial of long-term home-care benefits under the Medicaid-funded Choices for Care program, arguing that a second home on an adjacent piece of property should have been excluded from the financial-eligibility calculation. Given the language of the regulation, the legislative history that led to its promulgation, and the policy considerations attending the Medicaid program, the Supreme Court concluded that the Secretary correctly interpreted the home-exclusion rule when he reinstated the determination of the Department of Children and Families denying the benefits. Thus, the Court found no compelling indication of error in the Secretary’s determination and affirmed. View "In re Marilyn Clifford" on Justia Law

Appellant was a personal care attendant for a Medicaid beneficiary. Appellant was later charged with Medicaid fraud for submitting a false claim for his services. After a bench trial Appellant was convicted under Kan. Stat. Ann. 21-3846(a)(1) for defrauding the Medicaid program. The court of appeals reversed Appellant's conviction, holding that the complaint charged that Appellant submitted statements for services he did not provide while the evidence at trial established that Appellant actually did provide the services for which he submitted statements. The Supreme Court reversed the court of appeals and affirmed the district court, holding that sufficient evidence supported Appellant's conviction for Medicaid fraud.View "State v. McWilliams" on Justia Law

Plaintiffs, three plaintiff-classes and Sheila Perdue individually, brought a class action complaint seeking declaratory and injunction relief alleging violations of their federal statutory and constitutional rights. Plaintiffs challenged the Indiana Family and Social Services Administration's (FSSA) automated system of processing claims for Medicaid, Food Stamps, and Temporary Assistance to Needy Families benefits. The trial court held (1) the FSSA's denial notices satisfied due process; (2) the FSSA could not deny an application for Food Stamp benefits when the applicant failed to cooperate in the eligibility determination process; and (3) determined that the FSSA had failed to accommodate Perdue's disabilities in violation of the Americans with Disabilities Act and the Rehabilitation Act. The Supreme Court reversed in part and affirmed in part, holding (1) the FSSA's denial notices were insufficiently explanatory in violation of due process; (2) the FSSA may deny an application for Food Stamp benefit when the applicant fails to cooperate in the eligibility determination process; and (3) Perdue was entitled to reasonable accommodations in applying for benefits, but that did not necessarily require providing a caseworker or case management services.View "Perdue v. Gargano" on Justia Law

Main & Associates, Inc., d/b/a Southern Springs Healthcare Facility, filed an action in the Bullock Circuit Court, on behalf of itself and a putative class of Alabama nursing homes, against Blue Cross and Blue Shield of Alabama (BCBS), asserting claims of breach of contract, intentional interference with business relations, negligence and/or wantonness, and unjust enrichment and seeking injunctive relief. BCBS removed the case to the the federal court, arguing among other things, that Southern Springs' claims arose under the Medicare Act and that the Medicare Act, as amended by the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (the MMA) completely preempted Southern Springs' state-law claims. Southern Springs moved the federal court to remand the case to the circuit court, arguing that the federal court did not have jurisdiction over its claims. The federal court granted the motion and remanded the case to the Bullock Circuit Court. After remand, BCBS moved the circuit court for a judgment on the pleadings, arguing that Southern Springs had not exhausted its administrative remedies and that the circuit court did not have subject-matter jurisdiction over the case. The circuit court denied BCBS's motion, and BCBS petitioned the Supreme Court for a writ of mandamus to direct the circuit court to dismiss Southern Springs' claims. Upon review, the Court concluded that Southern Springs' claims were inextricably intertwined with claims for coverage and benefits under the Medicare Act and that they were subject to the Act's mandatory administrative procedures and limited judicial review. Southern Springs did not exhaust its administrative remedies, and the circuit court did not have jurisdiction over its claims. Therefore, the Court granted BCBS's petition and issue a writ of mandamus directing the circuit court to dismiss the claims against BCBS. View "Main & Associates, Inc. v. Blue Cross & Blue Shield of Alabama" on Justia Law

In enacting comprehensive welfare reform in 1996, Congress rendered various groups of aliens ineligible for federal benefits and also restricted states' ability to use their own funds to provide benefits to certain aliens. As a condition of receiving federal funds, Congress required states to limit eligibility for federal benefits, such as Medicaid, to citizens and certain aliens. Plaintiffs filed suit claiming that Basic Health Hawai'i violated the Equal Protection Clause of the Fourteenth Amendment because it provided less health coverage to nonimmigrant aliens residing in Hawai'i (COFA Residents) than the health coverage that Hawai'i provided to citizens and qualified aliens who are eligible for federal reimbursements through Medicaid. The court concluded that Congress has plenary power to regulate immigration and the conditions on which aliens remain in the United States, and Congress has authorized states to do exactly what Hawai'i had done here - determine the eligibility for, and terms of, state benefits for aliens in a narrow third category, with regard to whom Congress expressly gave states limited discretion. Hawai'i has no constitutional obligation to fill the gap left by Congress's withdrawal of federal funding for COFA Residents. Accordingly, the court vacated the district court's grant of a preliminary injunction preventing Hawai'i from reducing state-paid health benefits for COFA Residents because Hawai'i is not obligated to backfill the loss of federal funds with state funds and its decision not to do so was subject to rational-basis review. View "Korab v. Fink" on Justia Law

Plaintiffs placed their son in a specialized private school designed to educate children with learning disabilities and filed suit against the District for tuition reimbursement under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. An Impartial Hearing Officer (IHO) awarded tuition reimbursement but the State Review Officer (SRO) reversed. The court held that the SRO's decision was insufficiently reasoned to merit deference and deferred to the IHO's decision, which was more thorough and carefully considered. The court affirmed the dismissal of plaintiff's claim under Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 794, where the parents had not presented sufficient evidence of bad faith or gross misjudgment. View "C.L. v. Scarsdale Union Free Sch. Dist." on Justia Law

Plaintiffs filed suit against the Secretary of Health and Human Services (HHS) and the Commissioner of the Social Security Administration (SSA) raising constitutional challenges to the Patient Protection and Affordable Care Act (ACA), Pub. L. No 111-148, 124 Stat. 119; raising statutory challenges to actions of HHS and the Commissioner relating to the implementation of the ACA and prior Medical legislation; and attacking the failure of defendants to render an "accounting" that would alter the American people to the insolvency towards which Medicare and Social Security programs were heading. On appeal, plaintiffs challenged the district court's dismissal of their claims. The court rejected plaintiffs' claims that 26 U.S.C. 5000A, which was sustained as a valid exercise of the taxing power, violated the Fifth Amendment's prohibition of the taking of private property without just compensation and violated the origination clause. The court concluded that plaintiffs' substantive attack on the Social Security Program Operations Manual System (POMS) provisions was clearly foreclosed by its decision in Hall v. Sebelius, holding that the statutory text establishing Medicare Part A precludes any option not to be entitled to benefits. The court rejected plaintiffs' second statutory claim attacking an interim final rule. Finally, the court concluded that plaintiffs failed to provide a legal argument for their claims against the Commissioner and Secretary, and therefore, the court lacked jurisdiction over plaintiffs' claim to an "accounting." Accordingly, the court affirmed the judgment of the district court. View "Assoc. Amer. Physicians, et al. v. Sebelius, et al." on Justia Law

Plaintiffs, on behalf of their daughter, filed suit challenging the district's implementation of a new individualized education program (IEP) for their daughter under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. Determining that the daughter's case was not moot, the court concluded that the court need not decide whether the various notice requirements were satisfied because whatever notice deficiencies there could have been in this case, they did not warrant relief; there was no error in requiring the parents to present a complaint and demand a due process hearing because they disagreed with the IEP team's decision; the district court correctly stated the Loren F. ex. rel. Fisher v. Atlanta Independent School System standard, fully reviewed the administrative record, and independently analyzed each of the parents' claims; the district court did not abuse its discretion when it issued the parents' proposed order and then decided the case on summary judgment; and the court held that 42 U.S.C. 1983 actions for denial of rights conferred by the IDEA were barred because the IDEA's comprehensive enforcement scheme provided the sole remedy for statutory violations and, therefore, the district court did not err in dismissing the parents' section 1983 claims. Accordingly, the court affirmed the judgment of the district court. View "K.A. v. Fulton County Sch. Dist." on Justia Law