Anderson v. Dooley

District Court, N.D. California·Decided June 15, 2020·No. 4:15-cv-05120·Unknown

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 BRUCE ANDERSON, et al., Case No. 15-cv-05120-HSG

8 Plaintiffs, ORDER DENYING MOTION FOR PRELIMINARY INJUNCTION AND 9 v. MOTION FOR PARTIAL SUMMARY JUDGMENT, AND GRANTING 10 MARK GHALY, in his official capacity as MOTION TO QUASH Secretary of the CALIFORNIA 11 DEPARTMENT OF HEALTH AND Dkt. Nos. 51, 56, 57 HUMAN SERVICES, 12 Defendant. 13

14 Pending before the Court are a motion for partial summary judgment (“SJ Motion,” Dkt. 15 No. 56) and a motion for preliminary injunction (“PI Motion,” Dkt. No. 57) filed by Plaintiffs 16 Bruce Anderson, Robert Austin, John Wilson, and California Advocates for Nursing Home 17 Reform (“CANHR”) (collectively “Plaintiffs”), for which briefing is complete. Dkt. No. 60 (“SJ 18 Opp.”); Dkt. No. 62 (“PI Opp.”); Dkt. No. 65 (“SJ Reply”); Dkt. No. 67 (“PI Reply”). Defendant 19 Mark Ghaly (“Defendant”), in his official capacity as Secretary of the California Health and 20 Human Services Agency, has also filed a motion to quash (Dkt. No. 51, “Mot. to Quash”) a 21 subpoena served on California Governor Gavin Newsom (“Governor”), which the Court took 22 under submission on March 18, 2020.1 Dkt. No. 52. On May 8, 2020, the California Association 23 of Health Facilities (“CAHF”) filed a motion for leave to file an amicus curiae brief in support of 24 Defendant, which the Court granted. Dkt. Nos. 73, 74. For the reasons set forth below, the Court 25 DENIES the motion for partial summary judgment and the motion for preliminary injunction, and 26 27 1 GRANTS the motion to quash. 2 I. BACKGROUND 3 Federal law protects against nursing home resident discharge (also known as “dumping”) 4 by requiring states to provide residents with a fair hearing whenever they have been refused 5 readmission from a hospital. See 42 U.S.C. §§ 1395i3(c), (e)(3); 1396r(c), (e)(3).2 The Ninth 6 Circuit held that the right to a “hearing” includes the right to a meaningful result. Anderson v. 7 Ghaly, 930 F.3d 1066, 1076 (9th Cir. 2019). In California, the Office of Administrative Hearings 8 and Appeals (“OAHA”), a division of the Department of Health Care Services (“DHCS”), 9 conducts the hearing and issues an order. See Declaration of Jonathan Evans, M.D. (Dkt. No. 56- 10 7, “Evans Decl.”) ¶¶ 11-12. Once OAHA “issues its final order, it does not retain jurisdiction in 11 the matter and has no authority to enforce its own orders.” See Declaration of Anthony Chicotel 12 (Dkt. No. 56-9, “Chicotel SJ Decl.”) Ex. 2 (August 6, 2015 letter from OAHA Chief 13 Administrative Law Judge Stevenson). However, in at least one instance, Chief ALJ Stevenson 14 suggested that she would “find the proper people and programs within [the] Agency to determine 15 how to best address and resolve [the] issue.” Id. OAHA’s position is that it “is not an 16 enforcement division within [DHCS]” and is only the “hearing forum.” Id. Ex. 4 at 2 (August 21, 17 2015 letter from ALJ Stevenson). 18 The Centers for Medicare and Medicaid Services (“CMS”), the federal agency within the 19 U.S. Department of Health and Human Services (“HHS”) tasked with enforcing the provisions of 20 the Medicaid Act, has told the State of California that it “cannot advise [the California Department 21 of Public Health (“CDPH”)] or DHCS which department should enforce [] decisions,” but that 22 “the CMS regulations are clear that the State Agency must promptly make corrective actions.” Id. 23 Ex. 3 at 3-4 (May 17, 2012 letter from CMS in response to an inquiry regarding whether state 24 agencies are responsible for enforcing discharge appeals and hearing decisions on refusals to 25 admit); see also id. Ex. 7 (August 31, 2017 letter from CMS to CDPH stating that “CMS cannot 26

27 2 Section 1395i-3 applies to any facility that accepts Medicare reimbursement, while § 1396r 1 advise either CDPH or DHCS on which department should enforce Transfer/Discharge (TDA) and 2 Refusal to Readmit (RTR) decisions because CMS statute is silent about which state entity is 3 responsible.”).3 Similarly, in response to an inquiry from CDPH regarding “how far CMS would 4 expect . . . the state Medicaid agency to go in terms of enforcing a TDA (transfer and discharge) 5 decision,” HHS informed California that although “it is the State’s responsibility, not CMS’s, to 6 determine how best to implement the hearing process and to provide for readmission of an 7 individual if the hearing decision is favorable to him or her,” HHS is “unaware of any provisions 8 of the Act or the regulations that explicitly require the State to institute court actions in this 9 context.” Id. Ex. 6 (July 17, 2009 letter from Department of Health & Human Services to CDPH). 10 HHS has explained that “the state Medicaid agency may wish to involve the State survey 11 agency to investigate any complaints of improper discharges or refusals to readmit, and to deploy 12 any sanctions at their disposal that are warranted based on their findings.” Id. In its May 2012 13 letter, for example, CMS responded to a statement in CDPH’s letter indicating that “CDPH staff 14 will cite facilities at the ‘D’ level for findings of inappropriate discharge and refusal to readmit” by 15 noting that “[a]lthough this level of deficiency may fit some situations, our office does not want 16 the CDPH District Offices to feel this is the only severity and scope designation that can be used,” 17 and explaining that “[o]ther scope and severity levels may apply, including a ‘G’ level deficiency . 18 . . .” Id. Ex. 3 at 2. 19 CDPH also has taken the position that its “Licensing and Certification” program is not 20 bound by an OAHA TDA decision because it “is not a party involved in the proceedings,” which 21 are “between the resident and the facility.” Id. Ex. 5 at 2-3 (CDPH Memorandum dated Oct. 23, 22 2008). CDPH takes the position that “[n]either the facility nor the recipient has any further 23 administrative appeal rights under this process,” but recognizes that “[t]his does not mean that the 24

25 3 It appears undisputed that if CMS believes California’s process does not comply with the 26 requirements of the FNHRA, the federal government has the power to terminate the state’s Medicaid funding. See Anderson, 930 F.3d at 1074-75 (characterizing the Medicaid program as a 27 cooperative federalism program that is “necessarily phrased as a set of directives to states that 1 parties involved cannot pursue other remedies such as a writ to Superior Court.” Id. at 3. CDPH’s 2 policy is that it “does not issue citations based on the decisions alone,” but “does investigate the 3 same complaints that resulted in the resident’s request for a [] hearing,” and if a violation is found 4 “that warrants the imposition of state or federal remedies, those remedies may be applied.” Id. 5 CDPH states that it “is charged with enforcing a broader spectrum of State and Federal laws than 6 just those that pertain to transfer and discharge and for that reason, [Licensing and Certification] 7 may not reach the same conclusion as the TDA hearing decision.” Id. 8 DHCS and CDPH report directly to Defendant Ghaly. SJ Mot. at 4. Plaintiffs contend that 9 each of the individual Plaintiffs in this case won their fairness hearing. Id. at 11 (citing 10 Declaration of Sara Anderson (Dkt. No. 13-1, “Anderson Decl.”) ¶ 7; Declaration of Vera 11 Washington (Dkt. 13-3, “Washington Decl.”) ¶ 10; Declaration of Jeremy Wilson (Dkt. 15, 12 “Wilson Decl.”) ¶ 6). Plaintiffs also contend that each of the individual Plaintiffs obtained an 13 order from DHCS requiring the facility to readmit them. Id.

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