Justia Public Benefits Opinion Summaries

The Ninth Circuit reversed the dismissal of relators' qui tam action alleging that the College violated the False Claims Act (FCA), 31 U.S.C. 3729-3733, by knowingly providing false progress reports on students in order to keep grant monies. The panel held that the Tribe is not a "person" under the FCA. The panel remanded for further jurisdictional factfinding on whether the College was an arm of the Tribe that shares the Tribe's status for purposes of the FCA. View "United States ex rel Cain v. Salish Kootenai College, Inc." on Justia Law

The Ninth Circuit reversed the denial of disability benefits and held that the ALJ did not follow the appropriate methodology for weighing a treating physician's medical opinion. In this case, the panel explained that the ALJ should have credited the treating physician's opinion and found that plaintiff was disabled, and the district court erred by developing its own reasons to discount the treating physician's opinion, rather than reviewing the ALJ's reasons for substantial evidence. The panel held that substantial evidence did not support the ALJ's finding that plaintiff's symptoms were not as severe as she testified, particularly in light of the extensive medical record objectively verifying her claims. Because each of the "credit-as-true" factors in Garrison v. Colvin, 759 F.3d 995, 1020 (9th Cir. 2014), was satisfied, remand for the calculation and award of benefits was warranted. View "Trevizo v. Berryhill" on Justia Law

Dawn McGee, who was receiving public assistance in the form of SNAP benefits, and Helge Naber were an unmarried couple living together with their five collective children. When the Department of Health and Human Services learned that Naber was living with McGee it sent McGee a notice requesting income information for Naber. McGee did not send the requested information, and the Department terminated McGee’s benefits. The Board of Public Assistance and district court upheld the Department’s determination. The Supreme Court affirmed, holding that the Department was required to terminate McGee’s SNAP benefits when the household, including Naber, refused to provide the income information that the Department requested. View "McGee v. State Department of Public Health & Human Services" on Justia Law

The Eighth Circuit affirmed the denial of plaintiff's disability insurance benefits and supplemental security income. The court held that the ALJ clearly considered the Polaski factors in accessing plaintiff's subjective complaints and substantial evidence supported her determination that plaintiff's statements concerning her symptoms were not entirely credible. Furthermore, substantial evidence supported the ALJ's residual functioning capacity determination that plaintiff was able to perform medium work. View "Bryant v. Colvin" on Justia Law

Claimant sought permanent total disability benefits from the Multiple Injury Trust Fund. The Workers' Compensation Court of Existing Claims held that the claimant's combined injuries rendered the claimant permanently totally disabled and awarded benefits. The Multiple Injury Trust Fund appealed. On appeal, the Court of Civil Appeals reversed, finding claimant ineligible to claim benefits against the Multiple Injury Trust Fund as the claimant was not a "physically impaired person" at the time of the claimant's second on-the-job injury. The dispositive issue presented for the Oklahoma Supreme Court’s review was whether claimant met the statutory definition of a "physically impaired person" at the time of the claimant's second on-the-job injury for purposes of determining eligibility for Multiple Injury Trust Fund benefits. As a corollary, the Court considered whether a duly-executed settlement agreement (memorialized on a form prescribed by the Workers' Compensation Court) constituted an adjudication of the claimant's disabilities. The Court answered both questions in the affirmative. View "Multiple Injury Trust Fund v. Garrett" on Justia Law

The Eighth Circuit affirmed the denial of plaintiff's application for supplemental security income. The court held that a reasonable mind could find that the record supports the ALJ's determination that plaintiff did not meet Listing 11.17A; the ALJ reasonably found, based on the record as a whole, that plaintiff did not exhibit the deficits in adaptive functioning needed to meet Listing 12.05C; and the ALJ had ample reason to discount the opinion of plaintiff's treating physician and to rely instead on the opinions of the state agency medical consultants, which were more consistent with the medical evidence. View "Vance v. Berryhill" on Justia Law

Richard Culbertson was counsel for the four plaintiffs in these consolidated Social Security disability benefits cases. At issue in this appeal was the attorney's fees for Culbertson under 42 U.S.C. 406 and the Equal Access to Justice Act (EAJA), 28 U.S.C. 2412(d). The Eleventh Circuit held that the district court did not err in its interpretation and application of Dawson v. Finch, 425 F.2d 1192 (5th Cir. 1970) and by imposing a 24% cap on section 406 fees; it was necessary for the district court to add the requested section 406(b) fee together with his EAJA award; and the district court did not abuse its discretion and did not exceed its authority. Accordingly, the court affirmed the judgment. View "Wood v. Commissioner of Social Security" on Justia Law

Maxmed sought judicial review of the Secretary of Health and Human Services' determination that the Medicaid program overpaid Maxmed by almost $800,000 for home health care services rendered to Medicare beneficiaries. The Fifth Circuit held that the failure to record the random numbers used in the sample did not necessarily invalidate the extrapolation methodology; the Secretary did not act arbitrarily and capriciously in rejecting the challenge to the independence of the sampling units; Congress clearly envisioned extrapolation in overpayment determinations involving home health agencies like Maxmed, and the Secretary's reliance on extrapolation as a tool was justified; the district court did not abuse its discretion in denying Maxmed's motion to amend or alter the judgment; and the district court properly rejected Maxmed's due process claim. Accordingly, the court affirmed the district court's grant of summary judgment to the Secretary. View "Maxmed Healthcare, Inc. v. Price" on Justia Law

Elliott worked in a coal mine until 1993 and developed a chronic cough. Three after his retirement, he developed more acute breathing problems. Elliott sought Black Lung Benefits Act, 30 U.S.C. 901–45, benefits in 2012. Helen Mining conceded it was the responsible employer, but challenged Elliott’s entitlement to benefits. The parties stipulated that Elliott had a totally disabling respiratory impairment. Because Helen Mining conceded disability and because Elliott demonstrated more than 15 years of employment, the ALJ determined that section 921(c)(4) applied and that the other elements, including causation, would be presumed, and shifted the burden to Helen Mining. Helen Mining offered the opinions of two doctors, attributing Elliott’s respiratory impairment to adult-onset asthma unrelated to coal dust exposure. The ALJ did not find their testimony persuasive, concluded that Helen Mining had failed to rule out coal dust-induced pneumoconiosis as a cause of Elliott’s disability, and awarded benefits. The Benefits Review Board upheld the award. The Third Circuit affirmed, upholding the application of the 2013 regulation, specifying the standard a coal mine operator must meet to rebut the presumed element of disability causation, 20 C.F.R. 718.305(d)(1). The regulation permissibly fills a statutory gap and Helen Mining did not meet that rebuttal standard. View "Helen Mining Co v. Elliott" on Justia Law

Critical Access Hospitals are reimbursed by Medicare for the reasonable and necessary costs of providing services to Medicare patients. The Medicaid program requires states to provide additional (DSH) payments to hospitals that serve a disproportionate share of low-income patients, 42 U.S.C. 1396a(a)(13)(A)(iv). In Kentucky, DSH payments are matched at 70% by the federal government. Kentucky’s contribution to DSH programs comes from payments from state university hospitals and Kentucky Provider Tax, a 2.5% tax on the revenue of various hospitals, including Appellants, The amount of DSH payments a hospital receives is unrelated to the amount of KP-Tax it paid. During the years at issue, DSH payments covered only 45% of Appellants' costs in providing indigent care. Appellants filed cost reports in 2009 and 2010 claiming their entire KP-Tax payment as a reasonable cost for Medicare reimbursement. Previously, they had received full reimbursement; for 2009 and 2010, however, the Medicare Administrative Contractor denied full reimbursement, offsetting the KP-Tax by the amount of DSH payments Appellants received. The Provider Reimbursement Review Board and Centers for Medicare and Medicaid Services upheld the decision. The Sixth Circuit affirmed, reasoning that the net economic impact of Appellants’ receipt of the DSH payment in relation to the cost of the KP-Tax assessment indicated that the DSH payments reduced Appellants’ expenses such that they constituted a refund. View "Breckinridge Health, Inc. v. Price" on Justia Law