City of Cordova v. Medicaid Rate Commission

789 P.2d 346, 1990 Alas. LEXIS 38
CourtAlaska Supreme Court
DecidedMarch 30, 1990
DocketS-3030
StatusPublished
Cited by9 cases

This text of 789 P.2d 346 (City of Cordova v. Medicaid Rate Commission) is published on Counsel Stack Legal Research, covering Alaska Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Cordova v. Medicaid Rate Commission, 789 P.2d 346, 1990 Alas. LEXIS 38 (Ala. 1990).

Opinion

*348 OPINION

RABINO WITZ, Justice.

I. INTRODUCTION.

This appeal involves attempts by the Medicaid Rate Commission (“the Commission”) to recover $167,361.00 paid by the State to the City of Cordova, owner and operator of the Cordova Community Hospital (“Cordova”), and $26,036.56 paid to the Petersburg General Hospital (“Peters-burg”) for Medicaid services provided by the two hospitals during 1984-85.

II. FACTS AND PROCEEDINGS.

In 1983, the legislature adopted a prospective payment system for Medicaid. 1 Under the old, retrospective system, health care facilities were reimbursed by Medicaid based on the “reasonable costs” incurred by the facility for patient care. Under the new, prospective system, facilities are reimbursed by Medicaid at rates determined by the Commission in advance of the provision of services by the facilities. See AS 47.07.-070(a). The prospective system provides an incentive for facilities to minimize their costs because a facility providing a service at a cost less than the pre-determined rate is permitted to keep the difference (“earns a profit”), while a facility providing the service at a cost greater than the pre-deter-mined amount suffers a loss in the amount of the difference.

The hospitals submitted budgets and requests for prospective payment rates for their fiscal year (FY) 1985, ending June 30, 1985. These budget requests were reviewed by one of the Commission’s program budget analysts. A staff analysis for each of the two hospitals was performed and the budget analyst recommended prospective payment rates for each. The Commission thereafter adopted prospective payment rates for the two hospitals, and paid them for Medicaid services based on these rates.

In the summer of 1986, the Commission began to audit the budget forms and rate requests submitted by health care facilities, including those submitted by Cordova and Petersburg for FY85. Cordova’s field audit was conducted in January of 1987. The final audit report was completed in November of 1987. At its December 11, 1987, meeting, the Commission (whose members at this meeting included Mr. Randy Super, designated as a member of the Commission by the Department of Health and Social Services (DHSS) Commissioner Myra Mun-son) voted to accept the audit, which revealed that Cordova had been overpaid $167,361. 2

Petersburg’s FY85 audit began in October of 1986. This audit determined that Petersburg had been overpaid $26,036.56. At an informal hearing held on September 18, 1987, the Commission accepted the audit report and sought to recover the overpayment from Petersburg. Under protest, Petersburg paid the alleged $26,036.56 overpayment and filed a request for an administrative hearing.

Cordova filed suit in Anchorage superior court, and the superior court granted Cor-dova a temporary restraining order preventing the DHSS from recouping the overpayment from current claims payments. Petersburg then filed a motion to intervene as a party plaintiff. The motion was granted. The hospitals thereafter filed a motion for summary judgment and for a permanent injunction. The State filed an opposition to the motion. Among the State’s attachments to its opposition were affidavits signed by Millie Duxbury, Mary Ben-sen, and Sister Barbara Haase. The hospitals subsequently filed a motion to strike these affidavits on the ground that they failed to comply with the requirements of Civil Rule 56(e).

After hearing the parties’ arguments on the hospitals’ motion for summary judgment, the superior court rendered an oral *349 decision. The court first held that retroactive recoupment of overpayments was not available to the Commission because the relevant statute, AS 47.07.070(a), permits only prospective action. Second, although the Commission presently has authority under 7 AAC 43.693(d) (eff. 8/9/86, Reg. 99) to recoup overpayments, it did not have that authority under the applicable audit regulation, 7 AAC 43.700. Third, in a decision going to the heart of the present appeal, the superior court held:

Until 7 AAC 43.693(d) was promulgated, the Commission did not have any authority to act retrospectively, so if the Commission cannot go back into 1985 and reset the rates, what is its remedy? If the audit reveals error in the budget analysis or misrepresentation, these errors should be corrected by adjusting rates for the ensuing year or years. If the hospital has made a profit on Medicaid payments, then payments exceeded the reasonable costs incurred. If this profit were the result of some miscalculation or misrepresentation, it can be taken into account in subsequent years when the budget analys[t]s are calculating reasonable costs for the upcoming fiscal year. In adjusting the rates for the new year to account for errors made on Medicaid payments from previous years, the Commission is able to recover costs which were paid out in error without acting outside the scope of its authority. Therefore if there were miscalculations or misrepresentations the Commission's remedy is to make prospective adjustments to account for such errors.

The superior court also held that the DHSS Commissioner’s designation of Randy Super did not constitute an impropriety that would void the December 11,1987, hearing; the court concluded that this delegation of the Commissioner’s responsibilities to Mr. Super was authorized by AS 44.17.010.

The hospitals then filed a motion requesting that the superior court clarify its oral ruling. The hospitals also filed a motion for actual attorney’s fees and costs which was countered by the State’s motion for Rule 82 attorney’s fees and a motion to remand the case to the Commission.

The superior court denied the hospitals’ motion for clarification and entered an order denying attorney’s fees and costs to either party. 3 This appeal followed.

III. DISCUSSION.

The superior court’s decision to grant the State relief prospectively turns on its interpretation of AS 47.07.070. 4 That statute provides:

*350 (a) The commission shall determine prospectively the rate of payment to a health facility under this chapter and AS 47.25.120-47.25.300 based on a fair rate for reasonable costs incurred by the facility. The commission shall by regulation list the factors it considers in making its rate determinations under this section.
(b) In determining a rate of payment to a health facility under this section, the commission shall consider the proportionate share of the facility’s financial requirements for patient care for
(1) costs of current operations, including salaries and wages, purchased services, supplies, insurance, leases, depreciation, taxes, interest expense, maintenance and other health facility operating expenses; and
(2) education, research, and appropriate capital development.

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Bluebook (online)
789 P.2d 346, 1990 Alas. LEXIS 38, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-cordova-v-medicaid-rate-commission-alaska-1990.