B. Dunkelberger v. DHS

CourtCommonwealth Court of Pennsylvania
DecidedFebruary 17, 2026
Docket1236 C.D. 2024
StatusUnpublished
AuthorLeavitt

This text of B. Dunkelberger v. DHS (B. Dunkelberger v. DHS) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
B. Dunkelberger v. DHS, (Pa. Ct. App. 2026).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Bret Dunkelberger, : Petitioner : : v. : No. 1236 C.D. 2024 : Argued: December 8, 2025 Department of Human Services, : Respondent :

BEFORE: HONORABLE RENÉE COHN JUBELIRER, President Judge HONORABLE MICHAEL H. WOJCIK, Judge (P.) HONORABLE MARY HANNAH LEAVITT, Senior Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY SENIOR JUDGE LEAVITT FILED: February 17, 2026

Bret Dunkelberger (Dunkelberger) petitions for review of an adjudication of the Department of Human Services (Department) that denied his request for an exception from certain Department rules relating to the home and community-based services he receives. In doing so, the Department affirmed the decision of the Administrative Law Judge (ALJ) that because the challenged rules were established by regulation, the ALJ lacked authority to invalidate or modify them as requested. On appeal, Dunkelberger argues, inter alia, that the rules in question were not lawfully promulgated as regulations and, thus, are null and void. Upon review, we reverse the Department’s adjudication. Background I. Medicaid and Waiver Programs Medicaid is the nation’s primary health insurance program for low- income and high-need Americans. Enacted in 1965 and set forth at Title XIX of the Social Security Act, see 42 U.S.C. §§1396–1396w-6, Medicaid is jointly funded by the federal and state governments. Participation in Medicaid is optional, but once a state elects to participate, it must comply with Title XIX and its regulations. See Rehabilitation and Community Providers Association v. Department of Human Services Office of Developmental Programs, 283 A.3d 260, 262 (Pa. 2022). Medicaid is administered at the federal level by the Centers for Medicare & Medicaid Services (“CMS”), which is part of the United States Department of Health and Human Services. In Pennsylvania, Medicaid is administered by the Department and is known as Medical Assistance. The federal government requires states participating in Medicaid to provide certain mandated services to Medicaid enrollees. The federal government also authorizes waiver programs, which give states flexibility to operate outside federal rules. Waivers must be approved by CMS. Rehabilitation and Community Providers Association, 283 A.3d at 262. One category of waivers, authorized by Section 1915(c) of the Social Security Act, 42 U.S.C. §1396n, is known as Home and Community-Based Services and relates to long-term care. This waiver permits enrollees to receive care in their home or community rather than in an institutional setting. Rehabilitation and Community Providers Association, 283 A.3d at 262-63. The Department’s Office of Developmental Programs is responsible for funding and supervising the provision of services associated with Home and Community-Based Services waivers. II. Factual Background Dunkelberger suffers from several medical conditions and behavioral disorders, including severe autism, that require significant care. Currently 32 years old, he resides with his mother Kathleen Dunkelberger (Mother), and he receives

2 care through the Home and Community-Based Services waiver program. Mother is a direct service provider and has formed a corporation, “Bret’s Adventure,” which has been approved by Northumberland County Behavioral Health/Intellectual & Developmental Services (County Services) to provide care to Dunkelberger. Mother is an officer, and the only full-time employee, of Bret’s Adventure. An individual support plan (Support Plan) has been developed to address Dunkelberger’s needs, which has been in effect since 2017. The Support Plan is annually reassessed, updated, and approved by the Northumberland County Administrative Entity (Administrative Entity), an agent of the Department’s Office of Developmental Programs. The Support Plan has prescribed Dunkelberger approximately 98 hours of Home and Community-Based Services per week, or 14 hours per day. In October 2019, Tara Avellino (Avellino), a program specialist for County Services, advised Mother by email that she cannot be compensated for more than 40 hours of care per week. In addition, compensation for services rendered to Dunkelberger outside the Commonwealth while on vacation was capped at 30 days per year. Further, when relatives provide services to Dunkelberger, the combination of their hours cannot exceed 60 hours in any given week. Avellino advised that this rule, known as “the “40/60 rule,” “is very concrete and not subject to any interpretation and must be followed to the letter.” Reproduced Record at 35a (R.R. __). On October 22, 2019, Dunkelberger sought an exception to the 40/60 rule and the travel rule. By letter of October 30, 2019, the Office of Developmental Programs, by Deputy Secretary Kristen Ahrens, denied the request for the stated reason that an exception to the 40/60 rule exists only when there is an emergency or

3 an unplanned departure of a regularly scheduled worker, which Dunkelberger did not prove. As to the travel rule, the letter stated that it “has been in effect since July 1, 2009, and is not subject to a variance or exception process.” R.R. 10a. Dunkelberger appealed the rulings of Deputy Secretary Ahrens to the Department’s Bureau of Hearings and Appeals (Bureau of Appeals). The appeal alleged that the imposition of the “40/60 rule,” the travel rule, and limitation on family providers would limit his “current services and remove [his] choices.” Certified Record at 9 (C.R. __). Dunkelberger requested to be “grandfather[ed] in so [he] can continue [his] everyday life [and] services and/or remove these discriminatory reg[ulations] all together.” Id. The Bureau of Appeals appointed an ALJ to conduct a hearing. At the hearing, Mother testified that her son, who has been receiving waiver services since age 3, requires 24-hour care. Because the two reside in a rural area, it is hard to secure and retain care providers. Bret’s Adventure has hired staff from time to time, but no one has lasted very long. Mother is a registered nurse and testified that she is best suited to provide care to her son, who has thrived under her care. Mother testified that Dunkelberger has been approved for 12 and 14 hours of care per day and has been for many years. She first learned of the 40/60 rule in 2019 when she was contacted by Avellino. Mother requested copies of the 40/60 rule and travel rule, which Avellino provided. Mother then contacted Deputy Secretary Ahrens to request an exception; her request was denied. Mother testified that the rules will reduce her son’s care. She is the only person who can care for her son because other caregivers are not available in her area, which is rural.

4 Eileen Holobovich, Dunkelberger’s County-assigned support coordinator, who monitors his care on a monthly basis, testified that should Dunkelberger be placed in a community home, he would likely receive 24 hours of care a day, 7 days a week, from 2 staff members, which is more than the hours of care approved for Dunkelberger’s Support Plan. Notes of Testimony at 150-51, (N.T. __); C.R. 455-56. Holobovich testified that an institutional placement is not ideal for Dunkelberger because changing his routine could be “devastating” for him. N.T. 151; C.R. 456. Further, such a placement would not provide “the activities, the availability to go out when he needs to[,]” which he presently receives. Id. Avellino testified about the Department rules challenged by Dunkelberger. She explained that the 40/60 rule has been in effect, in one form or another, since 2015 or before.

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Bluebook (online)
B. Dunkelberger v. DHS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/b-dunkelberger-v-dhs-pacommwct-2026.