Chris Traylor, Commissioner, Texas Department of Aging and Disability Services The Texas Department of Aging and Disability Services Thomas Suehs, Executive Commissioner of the Texas Health and Human Services Commission v. Oakview Healthcare Residence, Ltd., D/B/A Oakview Healthcare Residence

CourtCourt of Appeals of Texas
DecidedMarch 8, 2013
Docket03-12-00072-CV
StatusPublished

This text of Chris Traylor, Commissioner, Texas Department of Aging and Disability Services The Texas Department of Aging and Disability Services Thomas Suehs, Executive Commissioner of the Texas Health and Human Services Commission v. Oakview Healthcare Residence, Ltd., D/B/A Oakview Healthcare Residence (Chris Traylor, Commissioner, Texas Department of Aging and Disability Services The Texas Department of Aging and Disability Services Thomas Suehs, Executive Commissioner of the Texas Health and Human Services Commission v. Oakview Healthcare Residence, Ltd., D/B/A Oakview Healthcare Residence) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Chris Traylor, Commissioner, Texas Department of Aging and Disability Services The Texas Department of Aging and Disability Services Thomas Suehs, Executive Commissioner of the Texas Health and Human Services Commission v. Oakview Healthcare Residence, Ltd., D/B/A Oakview Healthcare Residence, (Tex. Ct. App. 2013).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-12-00072-CV

Chris Traylor, Commissioner, Texas Department of Aging and Disability Services; The Texas Department of Aging and Disability Services; Thomas Suehs, Executive Commissioner of The Texas Health and Human Services Commission; and Texas Health and Human Services Commission, Appellants

v.

Oakview Healthcare Residence, Ltd., d/b/a Oakview Healthcare Residence, Appellee

FROM THE DISTRICT COURT OF TRAVIS COUNTY, 419TH JUDICIAL DISTRICT NO. D-1-GN-10-002298, HONORABLE ORLINDA NARANJO, JUDGE PRESIDING

MEMORANDUM OPINION

The Texas Department of Aging and Disability Services (DADS); Chris Traylor,

Commissioner of DADS; the Texas Health and Human Services Commission (HHSC); and Thomas

Suehs, Executive Commissioner of HHSC (jointly the State) challenge the district court’s judgment

reversing a final order of DADS following Oakview Healthcare Residence’s administrative appeal

of an administrative enforcement action. The order upheld changes made by HHSC, through its

Office of Inspector General, Utilization Review Division (OIG), to certain assessments of Medicare

recipients made by Oakview, a long term care facility, resulting in reduced Medicaid reimbursements

to Oakview. The State appeals the district court’s reversal of the DADS order and denial of its plea

to the jurisdiction. For the reasons that follow, we affirm in part and reverse and dismiss in part. FACTUAL AND REGULATORY BACKGROUND

Oakview is a licensed nursing facility that provides reimbursable Medicaid services

under a contract with DADS. See Tex. Health & Safety Code Ann. § 242.031 (West 2010);

Tex. Hum. Res. Code Ann. § 161.071(6) (West Supp. 2012); 40 Tex. Admin. Code §§ 46.1–.71

(Dep’t of Aging and Disability Servs., Contracting to Provide Assisted Living and Residential Care

Servs.) (West 2012).1 Oakview is required to perform assessments of the clinical condition and

functional performance of Medicaid recipients and the level of services provided to each. Prior to

October 3, 2008, the applicable assessment system was the Case Mix Classification System, which

consisted of eleven Texas Index for Level of Effort (TILE) classifications. See former 1 Tex.

Admin. Code §§ 371.212–.214 (West 2008) (Texas Health & Hum. Servs. Comm’n, Case Mix

Classification Sys., Utilization Review and Control Activities Performed by Texas Heath and Human

Services Commission (Commission), Texas Index for Level of Effort (TILE) Assessments) repealed

33 Tex. Reg. 8311 (2008) (proposed July 4, 2008).2 The TILE assessment scores determined the

amount of Medicaid reimbursement; the greater the level of effort required by the nursing facility,

the lower the score and the higher the reimbursement. Oakview was required to record the

assessments on Client Assessment Review and Evaluation (CARE) forms, submit them

electronically, and maintain copies. See id. § 371.212(7).

1 Except where material substantive changes have been made, we cite the current versions of the relevant statutory provisions and agency rules for convenience. 2 Unless otherwise stated, the repealed rules are cited as former 1 Tex. Admin. Code §§ 371.212–.214. All citations to title 1, chapter 371 of the Texas Administrative Code are to repealed or current rules issued by the Texas Health and Human Services Commission.

2 HHSC, through OIG, periodically conducts on-site utilization reviews and

investigations of fraud and abuse in nursing facilities that receive Medicaid funds. Id. §§ 371.213(a),

.214(c)(1); Tex. Gov’t Code Ann. § 531.102 (West 2012).3 Under the repealed TILE rules, during

the on-site visits, the facility was required to provide hard copies of the previously-submitted CARE

forms. Former 1 Tex. Admin. Code §§ 371.212 (7)(B), .213(b). CARE forms that could not be

located were considered invalid assessments. Id. § 371.212(7)(B). The first time the forms could

not be located, the lack of compliance was factored into the nursing facility’s “error rate.” Id. The

error rate determined the frequency of on-site visits, which could occur at intervals of between seven

and sixteen months. Id. § 371.214(d). Subsequent failures to locate CARE forms could result in a

default score of the highest TILE assessment (212) and therefore a reduced Medicaid reimbursement.

See id. § 371.212(6)(L), (7)(B).

On February 22, 2008, OIG conducted a routine on-site visit to Oakview, at which

time certain CARE forms were not provided. On October 9, 2008, the Case Mix Classification

System rules were repealed and replaced with rules adopting the Resource Utilization Group

Classification System (RUG). See current 1 Tex. Admin. Code §§ 371.212, .214 (West 2012)

(Minimum Data Set Assessments, Res. Utilization Group Classification Sys.). The RUG rules do

not require the use of CARE forms and do not contain a provision for assignment of a default high

score for failure to provide records during on-site visits. See id. On February 3, 2009, OIG

3 See also 1 Tex. Admin. Code §§ 371.214(n) (West 2012) (Minimum Data Set Assessments, Resource Utilization Group Classification Sys.) (current version of rule regarding utilizations reviews). The current rules that replaced the repealed rules are cited as current 1 Tex. Admin. Code §§ 371.212 and 371.214.

3 conducted another on-site visit to Oakview, at which time Oakview did not provide CARE forms

for certain recipients. OIG assigned a default score of 212 for each of those recipients, which

resulted in reduced reimbursement to Oakview.

PROCEDURAL BACKGROUND

Oakview sought informal reconsideration of OIG’s determination and provided the

missing CARE forms, but no changes were made to the TILE scores. See former 1 Tex. Admin.

Code § 371.214(c)(3). The Decision Rationale states that the CARE forms were submitted for

reconsideration with all of the required signatures, but “since the form is no longer effective, the

default TILE 212 value is upheld.” Oakview contested the findings and submitted a request for a

formal appeal to HHSC. See id. § 371.214(c)(4); 1 Tex. Admin. Code §§ 357.481(a) (West 2012)

(Texas Health & Hum. Servs. Comm’n, Application of this Subchapter) (hearings under subchapter

conducted in accordance with Texas Administrative Procedure Act (APA), Chapter 2001 of Texas

Government Code), .484 (West 2012) (Texas Health & Hum. Servs. Comm’n, Request for

Hearing).4 HHSC transferred the case to the State Office of Administrative Hearings (SOAH) and

requested that SOAH docket the case, naming DADS as the referring agency. See 1 Tex. Admin.

Code §§ 155.53 (West 2012) (State Office of Admin. Hearings, Request to Docket Case);5 357.482

(West 2012) (Definitions) (defining “referring agency” as “the HHSC agency taking the action and

that issues the notice of adverse action, or the state agency that otherwise refers the matter to the

4 All cites to title 1, chapter 357 of the Texas Administrative Code are to rules issued by the Texas Health and Human Services Commission. 5 All cites to title 1, chapter 155 of the Texas Administrative Code are to rules issued by the State Office of Administrative Hearings.

4 HHSC Appeals Division for a hearing”), .484(d) (Request for Hearing) (upon receipt of request for

hearing HHSC will transfer case to SOAH).6

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Chris Traylor, Commissioner, Texas Department of Aging and Disability Services The Texas Department of Aging and Disability Services Thomas Suehs, Executive Commissioner of the Texas Health and Human Services Commission v. Oakview Healthcare Residence, Ltd., D/B/A Oakview Healthcare Residence, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chris-traylor-commissioner-texas-department-of-aging-and-disability-texapp-2013.