Emily Fitzmorris, et al. v. New Hampshire Department of Health and Human Services Commissioner Lori Weaver, et al.

2023 DNH 036
CourtDistrict Court, D. New Hampshire
DecidedApril 17, 2023
Docket21-cv-25-PB
StatusPublished
Cited by5 cases

This text of 2023 DNH 036 (Emily Fitzmorris, et al. v. New Hampshire Department of Health and Human Services Commissioner Lori Weaver, et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Emily Fitzmorris, et al. v. New Hampshire Department of Health and Human Services Commissioner Lori Weaver, et al., 2023 DNH 036 (D.N.H. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Emily Fitzmorris, et al.

v. Case No. 21-cv-25-PB Opinion No. 2023 DNH 036 New Hampshire Department of Health and Human Services Commissioner Lori Weaver, et al.

MEMORANDUM AND ORDER

The plaintiffs in this putative class action are disabled individuals who

are enrolled in New Hampshire’s Choices for Independence (CFI) waiver

program, a Medicaid program administered by the New Hampshire

Department of Health and Human Services (DHHS). The CFI waiver

program provides home and community-based care services to adults who

otherwise would be Medicaid-eligible for nursing home care. The plaintiffs

claim that DHHS has failed to operate the CFI waiver program in a way that

ensures participants receive all of their authorized services.

The plaintiffs filed a complaint against DHHS and its Commissioner,

alleging that the defendants’ systemic failure to provide CFI waiver

participants with their authorized services violates the Medicaid Act, the

Americans with Disabilities Act, and the Rehabilitation Act. The plaintiffs

now move for class certification.

1 I. BACKGROUND

A. The CFI Waiver Program

“Medicaid is a cooperative federal-state program that provides medical

care to needy individuals.” Douglas v. Indep. Living Ctr. of S. Cal., 565 U.S.

606, 610 (2012). States wishing to participate in the program must submit a

“state Medicaid plan” that describes the services the state will provide and

explains how it will administer the program. See 42 U.S.C. § 1396a. The U.S.

Department of Health and Human Services must approve the plan before a

state is eligible to receive federal funds. See Douglas, 565 U.S. at 610. States

may apply for a “waiver” that exempts a state plan from certain

requirements. See 42 U.S.C. § 1396n. Obtaining a waiver enables the state to

establish a program to provide home and community-based services to

persons who would otherwise require institutional care. See id. at § 1396n(c);

see also 42 C.F.R. §§ 441.300 et seq.

New Hampshire established the CFI waiver program pursuant to such

a waiver. See Doc. 91-1 at 1-2. The program provides home and community-

based services to Medicaid-eligible adults who clinically qualify for nursing

home services, but “prefer to be cared for at home or in other settings less

acute than a nursing facility.” See N.H. Rev. Stat. Ann. §§ 151-E:1(II); 151-

E:3(I)(a). DHHS is the state agency “responsible for CFI waiver operations,

including waiver program monitoring.” Doc. 23-3 at 15.

2 DHHS implements the CFI waiver program through a network of eight

private case management agencies that are licensed and regulated by the

state. See Price v. Shibinette, 2021 DNH 179 at 5; Doc. 91-1 at 6. Once DHHS

determines that an individual is eligible for the program, the participant is

paired with a case management agency. N.H. Admin. R. He-E § 805.07. The

case management agency, in turn, determines what services are necessary to

meet the needs of the participant and then seeks DHHS authorization for

those services. Id. at §§ 801.05; 801.06. When authorization is received, the

case management agency is tasked with coordinating the participant’s waiver

services, which are delivered by private service providers. See id. at

§ 805.05(c)-(d). Case management agencies are responsible for “[e]nsur[ing]

that services . . . are being provided,” and must conduct a quarterly review of

their participants’ records in order to “evaluate the delivery of services.” Id.

at §§ 805.05(d)(2); 805.10(a). The agency must then “take any remedial action

necessary to address deficiencies in service delivery” identified in the

quarterly review. Id. at § 805.10(c). Nonetheless, case management agencies

retain considerable discretion in determining how best to ensure that

participants receive all their authorized services. See id. at §§ 805.05(d);

805.10(c). Notwithstanding the substantial involvement of private actors, the

proper administration of the CFI program remains the ultimate

responsibility of DHHS. See Price, 2021 DNH 179 at 27.

3 B. Statutory Requirements

Like all state Medicaid plans, the CFI waiver program must comply

with a number of federal statutes, including the Medicaid Act, the Americans

with Disabilities Act, and the Rehabilitation Act. Under the Medicaid Act, all

covered services must be furnished to eligible participants “with reasonable

promptness.” See 42 U.S.C. § 1396a(a)(8); see also 42 U.S.C. § 1396d(a)

(defining “medical assistance” to include “the care and services themselves”);

Rosie D. v. Romney, 410 F. Supp.2d 18, 27 (D. Mass. 2006); Lewis v. N.M.

Dep’t of Health, 275 F. Supp.2d 1319, 1344 (D.N.M. 2003). Whether a delay

in the provision of services is “reasonable” requires consideration of several

factors, including “[t]he urgency of an individual’s need, the health and

welfare concerns of the individual, the nature of the services required, the

potential need to increase the supply of providers, [and] the availability of

similar or alternative services[.]” See Murphy ex rel. Murphy v. Minn. Dep’t

of Human Servs., 260 F. Supp.3d 1084, 1107 (D. Minn. 2017) (quoting U.S.

Dep’t of Health & Human Servs., Olmstead Update No. 4, HCFA Update at 6

(Jan. 10, 2001)) (alterations in original).

The CFI waiver program must also comply with Title II of the

Americans with Disabilities Act (Title II), 42 U.S.C. §§ 12131 et seq., and

4 Section 504 of the Rehabilitation Act (Section 504), 29 U.S.C. §§ 794 et seq. 1

Both Title II and Section 504 prohibit discrimination on the basis of

disability. 42 U.S.C. § 12132; 29 U.S.C. § 794. One form of prohibited

discrimination is the “unjustified institutional isolation of persons with

disabilities.” See Olmstead v. L.C. ex rel. Zimring, 527 U.S. 581, 600 (1999).

Title II and Section 504 employ similar implementing regulations, two of

which are relevant here: the integration mandate and the methods of

administration regulation. 2

The integration mandate requires entities to “administer services,

programs, and activities in the most integrated setting appropriate to the

needs of qualified individuals with disabilities.” See 28 C.F.R. § 35.130(d); see

also 45 C.F.R. § 84

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
2023 DNH 036, Counsel Stack Legal Research, https://law.counselstack.com/opinion/emily-fitzmorris-et-al-v-new-hampshire-department-of-health-and-human-nhd-2023.