Chesapeake Hospital Authority v. Department of Medical Assistance Services

85 Va. Cir. 387, 2013 WL 5730599, 2012 Va. Cir. LEXIS 146
CourtChesapeake County Circuit Court
DecidedSeptember 27, 2012
DocketCase No. (Civil) CL12-426
StatusPublished
Cited by1 cases

This text of 85 Va. Cir. 387 (Chesapeake Hospital Authority v. Department of Medical Assistance Services) is published on Counsel Stack Legal Research, covering Chesapeake County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Chesapeake Hospital Authority v. Department of Medical Assistance Services, 85 Va. Cir. 387, 2013 WL 5730599, 2012 Va. Cir. LEXIS 146 (Va. Super. Ct. 2012).

Opinion

By Judge V. Thomas Forehand, Jr.

This matter is before the Court on Chesapeake Hospital Authority’s (“the Hospital”) Petition for Appeal from a Final Agency Decision dated December 19, 2011, from the Department of Medical Assistance Services (“DMAS” or “the Department”).

This appeal presents a single issue raised by the Hospital, which administered inpatient services to three Virginia Medicaid recipients: P.M.G., S.T., and J.M.C. The Hospital asserts thatthe Department improperly denied payment for the inpatient services it provided these recipients. The Department conducted a utilization review audit of twelve medical records requested from the Hospital. By letter dated October 29, 2010, the Department notified the Hospital that it had identified an overpayment in the amount of $364,491.91. On November 29, 2010, the Hospital filed an appeal request, and an Informal Fact-Finding Conference was held on February 8, 2011, as provided in the Virginia Code. An informal appeal decision was issued on May 23, 2011, which upheld the overpayment [388]*388amount of $3 64,491.91. By letter dated June 22,2011, the Hospital appealed the informal decision and a formal hearing was held before the appointed hearing officer, Frederick R. Gerson, Esquire. The Recommended Decision of Hearing Officer was issued on October 20, 2011, and both parties had the opportunity to file written exceptions on or before November 22, 2011. On December 19, 2011, the Director of DMAS issued the Final Agency Decision, to which this appeal was taken. The Final Agency Decision accepted in part and rejected in part the Hearing Officer’s Recommended Decision and provided that the overpayment amount of $3 64,491.91 was to be recalculated by the Department based upon its rulings.

The Petition for Appeal was filed in this Court on February 16, 2012. DMAS filed the administrative record in the matter on February 21, 2012, which, in a fate potentially worse than that of Gregor Samsa himself,1 the Court has carefully reviewed in its entirety. Both parties have, by counsel, presented arguments in their respective briefs and at the hearing on August 29, 2012.

I. Findings of Fact Accepted in the Final Agency Decision

A. Patient P.M.G.

Patient P.M.G. was admitted to inpatient hospital services on December 25, 2009. At the time of admission, P.M.G. was not Medicaid eligible, but became retroactively eligible on March 22,2010. The Hospital documented physician certification of the need for inpatient services within 24 hours of P.M.G.’s admission to the Hospital, on December 26, 2009. The Hospital’s medical records concerning P.M.G. were updated and/or amended to include recertification of the need for inpatient services on July 12, 2011. The date of P.M.G.’s hospital discharge was March 27,2010, the same date as the patient’s death; therefore, P.M.G. was admitted to the hospital for inpatient care services for a total of 92 days. DMAS reimbursed the Hospital $238,244.10 for the provided inpatient hospital services. Timely physician certification of P.M.G.’s need for admission and inpatient services existed for 59 days of P.M.G.’s admission to inpatient hospital care, and no timely physician certification or recertification existed for 33 days of P.M.G.’s admission.

B. Patient S.T.

Patient S.T. was admitted to inpatient hospital services on April 27, 2009. At the time of hospital admission, S.T. was not Medicaid eligible, but became retroactively eligible on July 28, 2009. The Hospital documented [389]*389physician certification of the need for inpatient services within twenty-four hours of S.T.’s admission to the Hospital, on April 27,2009. The Hospital’s medical records concerning S.T. were updated and/or amended to include recertification of the need for inpatient services on July 8, 2011. S.T. was discharged from the Hospital on July 14,2009; therefore, S.T. was admitted to the Hospital for inpatient care services for a total of 78 days. DMAS reimbursed the Hospital $120,722.93 for the provided inpatient hospital services. Timely physician certification of S.T.’s need for admission and inpatient services existed for 60 days of the recipient’s admission to inpatient hospital care, and no timely physician certification or recertification existed for 18 days of S.T.’s admission.

C. Patient J.M.C.

Patient J.M.C. was admitted to inpatient hospital services on May 21, 2010. The Hospital’s medical records concerning J.M.C. were updated and/or amended to include physician certification of the need for inpatient services on July 14, 2011. The Hospital’s medical records concerning J.M.C. prior to July 12, 2011, do not include recertification of the need for inpatient services. The Department reimbursed the Hospital $5,524.88 for inpatient hospital services provided to J.M.C.

II. Standard of Review

Virginia Code § 2.2-4027 provides, in part, that:

The burden shall be upon the party complaining of agency action to designate and demonstrate an error of law subject to review by the court. Such issues of law include: (i) accordance with constitutional right, power, privilege, or immunity, (ii) compliance with statutory authority, jurisdiction limitations, or right as provided in the basic laws as to subject matter, the stated objectives for which regulations may be made, and the factual showing respecting violations or entitlement in connection with case decisions, (iii) observance of required procedure where any failure therein is not mere harmless error, and (iv) the substantiality of the evidentiary support for findings of fact. The determination of such fact issue shall be made upon the whole evidentiary record provided by the agency if its proceeding was required to be conducted as provided in § 2.2-4009 or 2.2-4020 or, as to subjects exempted from those sections, pursuant to constitutional requirement or statutory provisions for opportunity for an agency record of and decision upon the evidence therein.

[390]*390Further, “[w]hen the decision on review is to be made on the agency record, the duty of the court with respect to issues of fact shall be limited to ascertaining whether there was substantial evidence in the agency record upon which the agency as the trier of facts could reasonably find them to be as it did.” Va. Code § 2.2-4027.

The “substantial evidence” standard is “designed to give stability and finality to the factual findings of administrative agencies.” Alliance to Save the Mattaponi v. Commonwealth Dep’t of Envtl. Quality, 270 Va. 423, 442, 621 S.E.2d 78, 88 (2005), cert. denied, 547 U.S. 1192 (2006). When applying the substantial evidence standard, a reviewing court is required to take into account “the presumption of official regularity, the experience and specialized competence of the agency, and the purposes of the basic law under which the agency has acted.” Va. Code § 2.2-4027; Alliance to Save the Mattaponi, 270 Va. at 442, 621 S.E.2d at 88. Further, a reviewing court may only reject an agency’s factual findings when, “on considering the record as a whole, a reasonable mind would necessarily come to a different conclusion.” Aegis Waste Solutions, Inc. v. Concerned Taxpayers of Brunswick Cnty., 261 Va.

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Cite This Page — Counsel Stack

Bluebook (online)
85 Va. Cir. 387, 2013 WL 5730599, 2012 Va. Cir. LEXIS 146, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chesapeake-hospital-authority-v-department-of-medical-assistance-services-vaccchesapeake-2012.