Justia Public Benefits Opinion Summaries

The Office of the Medicaid Inspector General (OMIG) terminated a physician's participation in the Medicaid program on the basis of a Bureau of Professional Medical Conduct (BPMC) consent order, in which the physician pleaded no contest to charges of professional misconduct and agreed to probation. Supreme Court annulled the OMIG's determination. The Appellate Division affirmed, concluding (1) the agency acted arbitrarily and capriciously in barring the physician from treating Medicaid patients when the BPMC permitted him to continue to practice; and (2) the OMIG was required to conduct an independent investigation before excluding a physician from Medicaid on the basis of a BPMC consent order. The Court of Appeals affirmed but for another reason, holding (1) the OMIG is authorized to remove a physician from Medicaid in reliance solely on a consent order between the physician and the BMPC, regardless of whether BPMC chooses to suspend the physician's license or OMIG conducts an independent investigation; but (2) because OMIG did not explain why the BPMC consent order caused it to exclude the physician from the Medicaid program, the agency's determination was arbitrary and capricious.View "Koch v. Sheehan" on Justia Law

Mother and Appellant/Cross-Appellee Lisa Kinney Lindstrom sought a ruling as to the number of "occurrences" for which the MCARE Fund is liable based on allegations that her physician failed to diagnose discrete in utero infections suffered by her twins, which caused severe injuries to both children. The Commonwealth Court granted summary judgment in favor of the MCARE Fund, holding that the physician's failure to diagnose Mother's infection constituted the single cause of the children's injuries, and, therefore, there was a single occurrence, limiting MCARE coverage to the statutory limit of one payment of $1 million. Upon review, the Supreme Court reversed, holding that the Commonwealth Court erred by granting summary judgment because there was a genuine issue of material fact as to whether the children's injuries arose from the physician's failure to diagnose a single infection, or whether the children's injuries resulted from the physician's failure to diagnose multiple infections from different organisms that infected each child in utero at different times. View "Kinney-Lindstrom v. MCARE Fund" on Justia Law

The Department of Health and Welfare appealed an order that disallowed its attempt to recover assets in a probate proceeding. The Department sought to recover assets of a dead Medicaid recipient for medical assistance payments made on the decedent's behalf from her widower. The magistrate court held that the Department could not reach the separate property of the decedent's spouse. Upon review, the Supreme Court concluded the Department was permitted to seek recovery from the decedent's community property that was transmuted to her widow as his separate property. View "In re Estate of Wiggins" on Justia Law

Plaintiffs, several nursing homes approved by the Iowa Department of Human Services (DHS) as Medicaid providers, submitted annual reports disclosing their income and expenses to DHS. DHS used the reports to calculate the Medicaid per diem reimbursement rates for the nursing homes. Some of the facilities' expenses were disallowed by DHS, and DHS reduced reimbursement rates accordingly. The facilities appealed the adjustments. The director of human services upheld the action. The district court affirmed. The court of appeals reversed, concluding that the DHS rules did not support its decision that the disputed costs were not allowable. The Supreme Court affirmed, holding that DHS's exclusion of the facilities' lab, x-ray, and prescription drug costs from the nursing homes' reports was based on an incorrect interpretation of its rules.View "Sunrise Ret. Cmty. v. Iowa Dep't of Human Servs." on Justia Law

Claimant William Stewart appealed a decision of the appeal tribunal, as affirmed by the appellate board of the New Hampshire Department of Employment Security (DES) that denied his application for unemployment benefits. Stewart worked as the code enforcement director for the City of Laconia from March 14 to June 29, 2011. Following his termination, Stewart applied for unemployment benefits. A DES certifying officer denied the application. The officer determined that Stewart did not have annual earnings of at least $1,400 in two of four quarters of his alternate base period. Stewart appealed the decision to the tribunal. He argued that he had earnings of at least $1,400 in both the third and fourth quarters of his alternate base period. Following a hearing, the tribunal affirmed the decision denying Stewart’s claim. Stewart argued on appeal to the Supreme Court that the tribunal erred in concluding that he had insufficient quarterly earnings under RSA 282-A:25 to establish a claim for benefits. Upon review, the Supreme Court reversed and remanded, finding that DES’s reliance on its decision in "Appeal of Tennis" was misplaced. View "Appeal of William Stewart" on Justia Law

The North Dakota Department of Human Services appealed a district court order reversing and remanding the Department's order decreasing Plaintiff-Appellee Penne Nienow's monthly Supplemental Nutrition Assistance Program ("SNAP") benefits. The County determined Nienow received income from a prior mineral rights lease and, therefore, the 2011 payment was a recurring lump-sum payment. The County reduced Nienow's SNAP benefits to $16 per month. Nienow filed a request for hearing to the Department, and an evidentiary hearing was held. The County's representative testified Nienow stated that she leased the mineral rights and received income from the lease every five years and that she had leased the rights at least once before. After the hearing, the administrative law judge ("ALJ") concluded the County correctly determined Nienow's income and properly reduced her SNAP benefits. The Department adopted the ALJ's findings and conclusions. Nienow appealed the Department's order to the district court. The district court reversed and remanded, concluding Nienow's payment was a mineral leasing bonus, a nonrecurring lump-sum payment, and should not have been considered as income in determining Nienow's eligibility. Upon review of the matter, the Supreme Court reversed the district court order and reinstated the Department's final order reducing Nienow's SNAP benefits. View "Nienow v. Anderson" on Justia Law

Claimants appealed a district court judgment that affirmed Job Service of North Dakota's decision to deny them unemployment benefits. Upon review of the administrative record and the plain language of N.D.C.C. 52-06-02(4), the Supreme Court concluded that claimants were only disqualified from unemployment compensation for employee-initiated work stoppages due to labor disputes, not to locked out Claimants as in this case. Accordingly, the Court reversed the district court's judgment and remanded the case back to Job Service for further proceedings.View "Olson v. Job Service" on Justia Law

Appellant, a forty-eight-year-old who lived independently for two decades, had "borderline intellectual functioning," an expressive language disorder, and a learning disorder. Appellant applied for Home and Community Based Services (HCBS), a federal-state Medicaid Waiver program that provides assistance to individuals with developmental disabilities. The South Dakota Department of Human Services (the Department) denied Appellant's application, determining that Appellant was not eligible for HCBS. After a hearing, an ALJ affirmed the Department's denial. The circuit court affirmed. The Supreme Court also affirmed, holding that the ALJ did not clearly err in finding that Appellant did not qualify for benefits, as the evidence indicated that Appellant was a generally independent client who was able to function with little supervision or in the absence of a continuous active treatment program.View "Nelson v. Dep't of Social Servs." on Justia Law

Appellant Habib Sadid, a former tenured professor of civil engineering at Idaho State University, appealed an Industrial Commission Order that reversed the Department of Labor Appeals Examiner's grant of unemployment benefits to Appellant after he was terminated by Idaho State University. Upon review, the Supreme Court concluded that the Commission's finding of misconduct was supported by substantial and competent evidence. As such, the Court affirmed the Industrial Commission's order.View "Sadid v. Idaho State University" on Justia Law

Plaintiff Pamela Mattison, gave birth to twins who were conceived by artificial insemination after their father, Jeffery Mattison, had died. She sought social security survivors' benefits for the children based on Jeffery's earnings. The Social Security Administration denied her application, and an administrative law judge affirmed that decision. Plaintiff then filed an action in the United States District Court for the Western District of Michigan challenging the decision. That court has asked the Michigan Supreme Court to rule on whether the children could inherit from Jeffery under Michigan intestacy law. Having heard oral argument, the Supreme Court granted the district court's request to answer the question and held that under Michigan intestacy law, plaintiff's children could not inherit from Jeffery. The matter was returned to the district court for further proceedings. View "In re Mattison v. Social Security Comm." on Justia Law