Charleston Memorial Hospital v. Conrad

693 F.2d 324
CourtCourt of Appeals for the Fourth Circuit
DecidedNovember 11, 1982
DocketNo. 82-1351
StatusPublished
Cited by22 cases

This text of 693 F.2d 324 (Charleston Memorial Hospital v. Conrad) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Charleston Memorial Hospital v. Conrad, 693 F.2d 324 (4th Cir. 1982).

Opinion

ERVIN, Circuit Judge:

The South Carolina Hospital Association, 39 individual providers of hospital services participating in the South Carolina Medical Assistance Program, and two South Carolina residents (“appellants”) brought this action seeking declaratory and injunctive relief against the South Carolina Department of Social Services (“DSS”) and the United States Secretary of Health and Human Services (“HHS”). The action arose out of [326]*326certain administrative actions reducing Medicaid coverage. The district court, with the consent of the parties, issued a preliminary injunction on December 28, 1981, pending a hearing on the merits. Following a hearing on January 27-28, 1982, the district court entered an order dissolving the preliminary injunction and denying all permanent injunctive and declaratory relief requested by the plaintiffs. We affirm.

I.

A.

Title XIX of the Social Security Act, 42 U.S.C. § 1396 et seq. (1974) (“the Act”), provides for the establishment of cooperative federal-state programs, commonly known as “Medicaid,” “[f]or the purpose of enabling each state, as far as practicable under the conditions in each state, to furnish” medical assistance to certain individuals 1 “whose income and resources are insufficient to meet the costs of necessary medical services.” 42 U.S.C. § 1396 (1974). States that elect to participate in the Medicaid program are eligible to receive matching funds from the federal government if the state establishes a “state plan” for medical assistance that comports with statutory and regulatory requirements under the Act. 42 U.S.C. § 1396b. See 42 U.S.C. § 1396a(a)(l)-(44) (1974); 42 C.F.R. § 447 et seq.

Section 1396d(a)(l)-(5) requires participating states to provide for inpatient hospital services, outpatient hospital services, other laboratory and x-ray services, skilled nursing facilities, and physicians’ services. The extent of medical assistance provided by the state for each of the services must be “sufficient in amount, duration, and scope to reasonably achieve its purpose.” 42 C.F.R. § 440.230(b). See also 42 U.S.C. § 1396a(a)(10) (1974).

A state has broad discretion, however, in developing standards for determining the extent of coverage it will provide in each of the mandatory categories. See Beal v. Doe, 432 U.S. 438, 444, 97 S.Ct. 2366, 2370, 53 L.Ed.2d 464 (1977). Section 1396a(a)(17) requires only that a state plan for medical assistance “include reasonable standards ... for determining ... the extent of medical assistance under the plan which . . . are consistent with the objectives of [the Act].”2

Once a state establishes the extent of coverage it will provide in each of the mandatory categories, it must determine the rate at which it will reimburse medical providers for the covered services. Section 1396a(a)(13)(A) of the Act requires that state plans provide

for payment ... of the hospital, skilled nursing facility, and intermediate care facility services approved under the plan through the use of rates (determined in accordance with methods and standards developed by the State and which, in the case of hospitals, take into account the situation of hospitals which serve a disproportionate number of low income patients with special needs.. .) which the State finds and makes assurance satisfactory to the Secretary, are reasonable and adequate to meet the cost which must be incurred by efficiently and economically operated facilities in order to provide care and services in conformity with applicable State and Federal laws, regulations, and quality and safety standards and to assure that individuals eligible for medical assistance have reasonable access (taking into account geographic location and reasonable travel time) to inpatient hospital services of adequate quality. .. ,3

Thus, a state plan must provide for reimbursement to hospitals at a rate that:

[327]*327(1) is determined in accordance with methods and standards developed by the state;
(2) takes into account the situation of hospitals which serve a disproportionate number of low income patients with special needs;
(3) is reasonable and adequate to meet the costs that are incurred by efficiently and economically operated facilities; and
(4) assures that eligible Medicaid recipients will have reasonable access to inpatient hospital services of adequate quality-

If a state plan comports with the foregoing requirements, along with the other requirements under the Act, the Secretary must approve it. 42 U.S.C. § 1396a(b) (1974); Arizona State Dep’t of Public Welfare v. Dep’t of Health Education and Welfare, 449 F.2d 456, 461 (9th Cir.1971), cert. denied, 405 U.S. 919, 92 S.Ct. 945, 30 L.Ed.2d 789 (1972). Once approved, a state plan is subject to continual scrutiny by the Secretary to ensure continued compliance with federal requirements. Id. Amendments to a state plan also must be submitted to the Secretary for review. 45 C.F.R. § 201.3.

B.

The state of South Carolina participates in the Medicaid program under an approved state plan. DSS, the state agency responsible for administering the South Carolina Medicaid program, requested the state legislature to allocate $260 million for its proposed health care budget for the 1982 fiscal year (July 1, 1981 — June 30, 1982). Of the $260 million budget, DSS had projected the cost of inpatient and outpatient hospital services at $84 million. Thereafter, the legislature appropriated only $232.6 million for Medicaid, which resulted in a reduction of funds available for inpatient and outpatient services from the projected $84 million to $67 million.4

DSS responded to the deficient appropriation by implementing a series of reductions in medical services that became effective July 1, 1981. Among the proposed reductions were a reduction in inpatient hospital coverage from 40 to 18 days per Medicaid recipient per year5 and a reduction in outpatient hospital visits from an unlimited number to 18 per Medicaid recipient per year. The rate at which hospitals were to be reimbursed for the days covered, however, was not changed.

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Bluebook (online)
693 F.2d 324, Counsel Stack Legal Research, https://law.counselstack.com/opinion/charleston-memorial-hospital-v-conrad-ca4-1982.