Armando D. v. State Department of Health Services

21 Cal. Rptr. 3d 66, 124 Cal. App. 4th 13, 2004 Daily Journal DAR 10181, 2004 Cal. App. LEXIS 1907
CourtCalifornia Court of Appeal
DecidedNovember 15, 2004
DocketA104965, A106082
StatusPublished
Cited by15 cases

This text of 21 Cal. Rptr. 3d 66 (Armando D. v. State Department of Health Services) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Armando D. v. State Department of Health Services, 21 Cal. Rptr. 3d 66, 124 Cal. App. 4th 13, 2004 Daily Journal DAR 10181, 2004 Cal. App. LEXIS 1907 (Cal. Ct. App. 2004).

Opinion

*16 Opinion

SEPULVEDA, J.

The State Department of Health Services and its Director, Sandra Shewry (the Department), challenge a writ of mandate and various orders issued by the trial court ordering the Department to operate its Child Health & Disability Prevention Gateway program (the Gateway program) in a particular manner, as being without any statutory or legal authority. 1 At issue is whether the Department had a clear, present, and ministerial duty to: (1) refrain from terminating the benefits of the Gateway program enrolled infants without a prior redetermination of eligibility; (2) take actions to identify infants entering through the Gateway program who could be deemed eligible for Medi-Cal; or (3) “reinstate” Medi-Cal benefits to infants whose presumptive eligibility period has ended. Finding no clear, present, and ministerial duty justifying the issuance of the writ and related orders, we reverse.

BACKGROUND

This appeal involves the manner in which an infant’s eligibility for medical benefits is established under federal and state law. Title XIX of the Social Security Act (42 U.S.C. §§ 1396—1396s), commonly known as Medicaid, is a cooperative federal-state program designed to provide medical assistance to individuals with insufficient income and resources to meet the costs of necessary medical care. (42 U.S.C. § 1396.) Medi-Cal is the state implementation of the federal Medicaid program, and is administered by the Department. (Welf. & Inst. Code, §§ 10721, 14000 et seq.; Cal. Code Regs., tit. 22, § 50004.) The case at bar involves the “deemed eligibility” and “presumptive eligibility” provisions set forth in federal and state law.

A. Deemed Eligibility.

A baby bom to a mother eligible for and receiving Medi-Cal is “deemed eligible” for Medi-Cal benefits for one year so long as the child lives with his or her mother and the mother remains (or would have remained if she were still pregnant) eligible for Medi-Cal. 2 (42 U.S.C. § 1396a (e)(4); Cal. Code Regs., tit. 22, § 50262.3.) Infants meeting the statutory criteria are automatically deemed to have applied for Medi-Cal and to have been found eligible for Medi-Cal without submitting a separate application and Social Security identification number. (42 U.S.C. § 1396a(e)(4); Cal. Code Regs., tit. 22, § 50262.3.)

*17 Eligibility for Medi-Cal, including deemed eligibility, is established by local county services agencies (also referred to as welfare agencies). (Cal. Code Regs., tit. 22, § 50101.) Neither state nor federal law specifies how qualifying infants must be located, identified, confirmed, or enrolled as “deemed eligible.” (See 42 U.S.C. § 1396a (e)(4); Cal. Code Regs., tit. 22, § 50262.3.) The Department and county agencies have various procedures in place to confirm deemed eligibility, including instructing pregnant women receiving Medi-Cal to contact the county once the infant is bom, contacting women who fail to contact the county before the end of the expected birth month, and encouraging health care providers, as well as parents, to use a simple, one-page newborn referral form.

All established Medi-Cal beneficiaries, including deemed eligible infants, are entitled to continue their benefits until they are found to be ineligible by a redetermination of eligibility by the county. (Welf. & Inst. Code, § 14005.37, subds. (a) & (d); 42 C.F.R. § 435.930.) Eligibility remains throughout the redetermination process. (Welf. & Inst. Code, § 14005.37, subd. (d).) If the information obtained through the redetermination process does not indicate a basis for eligibility, benefits may be terminated so long as due process requirements have been met. (Id. at § 14005.37, subd. (I); Cal. Code Regs., tit. 22, § 50179, subd. (a).)

B. Presumptive Eligibility and the Gateway Program.

Presumptive eligibility is an optional federal program through which low-income uninsured children up to age 19 may obtain temporary Medi-Cal benefits before their eligibility for ongoing Medi-Cal has been determined. (42 U.S.C. § 1396r-la; Welf. & Inst. Code, § 14011.7.) California implemented the Gateway program on July 1, 2003, as a vehicle for establishing presumptive eligibility, also referred to as “pre-enrollment.” 3 The Gateway program expanded health care coverage by drawing in uninsured children under the age of 19 from families with incomes of up to 200 percent of the federal poverty level, and to encourage them to apply for ongoing coverage in the Medi-Cal and Healthy Families programs. 4 The Department refers to the Gateway program as providing a temporary safety net for indigent children to receive benefits.

The Gateway program is an electronic enrollment process that immediately establishes presumptive eligibility at health care provider offices. 5 Health care *18 providers utilize an electronic form to pre-enroll children through the Gateway program using the Internet or a point of service device. Presumptive eligibility initiated through the Gateway program provides temporary full-scope Medi-Cal benefits for two months. (Welf. & Inst. Code, §§ 14011.7, subd. (f), 14011.8, subd. (a).)

Under state and federal law, temporary presumptive eligibility (or preenrollment) benefits provided through the Gateway program automatically terminate at the end of the second month, unless an application for benefits is submitted. (42 U.S.C. § 1396r-la (b)(2)(B); Welf. & Inst. Code, § 14011.8, subd. (a).) If an application is submitted, presumptive eligibility benefits continue until it is determined whether the child is eligible for ongoing Medi-Cal or Healthy Families coverage. (42 U.S.C. § 1396r-la (b)(2)(B); Welf. & Inst. Code, §§ 14011.7, subd. (e)(4), 14011.8, subd. (b).) If an application is not submitted, the temporary benefits end without the necessity of further review or determination by the Department. (Welf. & Inst. Code, § 14011.8, subd. (a).)

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Bluebook (online)
21 Cal. Rptr. 3d 66, 124 Cal. App. 4th 13, 2004 Daily Journal DAR 10181, 2004 Cal. App. LEXIS 1907, Counsel Stack Legal Research, https://law.counselstack.com/opinion/armando-d-v-state-department-of-health-services-calctapp-2004.