Charles W. Palian v. Department of Health and Human Services

2020 ME 131, 242 A.3d 164
CourtSupreme Judicial Court of Maine
DecidedNovember 10, 2020
StatusPublished
Cited by8 cases

This text of 2020 ME 131 (Charles W. Palian v. Department of Health and Human Services) is published on Counsel Stack Legal Research, covering Supreme Judicial Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Charles W. Palian v. Department of Health and Human Services, 2020 ME 131, 242 A.3d 164 (Me. 2020).

Opinion

MAINE SUPREME JUDICIAL COURT Reporter of Decisions Decision: 2020 ME 131 Docket: Ken-19-221 Argued: December 6, 2019 Decided: November 10, 2020

Panel: MEAD, GORMAN, JABAR, HUMPHREY, HORTON, and CONNORS, JJ., and CLIFFORD, A.R.J.*

CHARLES W. PALIAN

v.

DEPARTMENT OF HEALTH AND HUMAN SERVICES

CONNORS, J.

[¶1] Charles W. Palian, DMD, appeals from a judgment of the Superior

Court (Kennebec County, Stokes, J.) denying his petition for judicial review of

final agency action, M.R. Civ. P. 80C, and affirming the decision of the

Commissioner of the Department of Health and Human Services accepting the

recommendation of an administrative presiding officer that the Department

correctly established and maintained a claim in the amount of $116,852.05

against Dr. Palian.

* Although Chief Justice Saufley participated in the appeal, she resigned before this opinion was certified. Justice Alexander also participated in the appeal, but he retired before this opinion was certified. Although not present at oral argument, Justice Horton, Justice Connors, and Active Retired Justice Clifford participated in the development of this opinion. See M.R. App. P. 12(a)(2) (“A qualified Justice may participate in a decision even though not present at oral argument.”). 2

[¶2] We reject the bulk of Dr. Palian’s arguments, but remand as to one

aspect of the Department’s decision, which imposed the maximum allowable

penalties for Dr. Palian’s failure to adequately document time spent with

patients following his administration of anesthesia.

I. BACKGROUND

[¶3] The following undisputed facts are drawn from the presiding

officer’s recommended decision, and the procedural facts are taken from the

court’s record. See Manirakiza v. Dep’t of Health & Hum. Servs., 2018 ME 10, ¶ 2,

177 A.3d 1264.

[¶4] Until he retired in 2013, Dr. Palian was an oral surgeon and

MaineCare provider1 whose practice, Central Maine Oral and Maxillofacial

Surgery Associates, P.A. (Central Maine), was based in Auburn. In late 2014,

after Dr. Palian’s retirement, the Department initiated a post-payment review

of claims that Dr. Palian had submitted for reimbursement.2 The review was

conducted by Valerie Hooper, an employee in the Department’s Program

Integrity Unit. In October 2015, based on Hooper’s post-payment review, the

1Dr. Palian signed a MaineCare/Medicaid provider agreement in September 2009, contractually obligating him to adhere to MaineCare’s rules and regulations. 2The Department randomly selected 100 dates of service within an identified review period of September 1, 2010, to December 31, 2013. 3

Department issued a notice of violation (NOV), alleging that Dr. Palian had been

overpaid by $189,770.08.3

[¶5] By statute, 22 M.R.S. § 42(7) (2020), and pursuant to the MaineCare

Benefits Manual, see generally 10-144 C.M.R. ch. 101, ch. I, § 1 (effective

Sept. 17, 2018),4 an administrative challenge to an NOV is multi-tiered. A

provider may first request an informal review to be conducted by the Director

of MaineCare Services or a designated Department representative who was not

involved in the decision under review. Id. § 1.23-1. After obtaining an informal

review decision, if the provider remains dissatisfied, he or she may request an

administrative hearing before a presiding officer. Id. § 1.23-1(A). The presiding

officer then issues a written decision to the provider or a written

recommendation to the Commissioner of Health and Human Services, who

makes the final decision. Id. The final decision may be appealed to the Superior

3 The NOV cited the following violations of MaineCare rules and regulations: (1) improper or incomplete documentation with respect to interpreter services, radiographs, anesthesia recovery times, tooth numbers for tooth extractions and dates of service; (2) improper coding for nonemergency hospital procedures; (3) improper coding for Versed, Fentanyl, Ketamine, Propofol, and Valium; (4) billing for drugs above acquisition cost; (5) duplicate payments, payments for services covered through primary insurance, or payments not billed to primary insurance; (6) improper coding for comprehensive oral evaluation; and (7) improper coding for alveoplasty when fewer than four teeth per quadrant were extracted. 4 During the periods of time relevant to this appeal, 10-144 C.M.R. ch. 101, ch. I, § 1 was amended several times, most recently on September 17, 2018. None of the amendments is relevant to the issues presented on appeal, and the parties do not contend that any of the amendments affect our analysis. 4

Court in accordance with the Maine Administrative Procedure Act. Id.;

see 5 M.R.S. § 11001 (2020).

[¶6] Dr. Palian requested an informal review in which he responded to

the Department’s allegations and argued that the Department failed to pay him

for multiple claims that he submitted for reimbursement. Hooper reviewed and

prepared responses to Dr. Palian’s request, consulted with Herbert Downs,

director of the Department’s Division of Audit, and provided to Downs a draft

letter of decision for his use in the informal review. Downs issued his final

informal review decision in August 2016, adopting Hooper’s draft letter, which

revised the overpayment calculation to $147,329.89 based on the arguments

raised by Dr. Palian.

[¶7] Dr. Palian timely requested an administrative hearing, which was

held on July 17, 2017, and January 9, 2018. Based on evidence presented at the

hearing, and before a decision was issued by the presiding officer, the

Department reduced its total claim to $116,852.05. Before the hearing, the

Department had imposed penalties of 100% for lack of documentation of

anesthesia recovery times. Those penalties were upheld at the informal review

stage because Dr. Palian’s records did not indicate that he spent any time with

MaineCare patients after administering anesthesia. Following the hearing, the 5

Department reduced these anesthesia penalties from 100% to 20% because it

accepted Dr. Palian’s testimony that his standard practice was to remain with

patients as the standard of care required.

[¶8] The presiding officer issued a recommended decision on

June 5, 2018, upholding the Department’s recoupment claim for $116,852.05,

as provided in a revised recoupment demand spreadsheet submitted after the

hearing. In so recommending, the presiding officer concluded that Hooper’s

assistance of Downs in conducting the informal review did not violate

Dr. Palian’s procedural rights; the Department was not equitably estopped

from maintaining its claims; and Dr. Palian failed to preserve his argument

regarding penalties for improperly documented claims, except with respect to

the 20% penalties for improper documentation of anesthesia recovery time

because those penalties were not in effect at the time of the informal review.

[¶9] Dr. Palian filed responses and exceptions to the presiding officer’s

recommended decision on June 19, 2018. Two weeks later, Commissioner

Ricker Hamilton issued a one-sentence final decision adopting the presiding

officer’s recommended decision in full.5 Dr. Palian timely appealed the

5 Although the Commissioner’s final decision is the decision of the fact-finding agency, because the Commissioner adopted the presiding officer’s recommended decision with no further explanation, the recommended decision contains the relevant findings of fact and conclusions of law. 6

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Bluebook (online)
2020 ME 131, 242 A.3d 164, Counsel Stack Legal Research, https://law.counselstack.com/opinion/charles-w-palian-v-department-of-health-and-human-services-me-2020.