Heartz v. Morton

CourtDistrict Court, D. New Hampshire
DecidedJanuary 8, 1999
DocketCV-98-317-B
StatusPublished

This text of Heartz v. Morton (Heartz v. Morton) 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
Heartz v. Morton, (D.N.H. 1999).

Opinion

Heartz v . Morton CV-98-317-B 01/08/99

UNITED STATE DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Bruce Heartz

v. Civil N o . 98-317-B

Terry Morton, et. a l .

MEMORANDUM AND ORDER

Bruce Heartz, a Medicaid recipient with an acquired brain disorder, brings this action for declaratory and injunctive relief against the state officials who administer New Hampshire’s Medicaid program. Heartz argues that the state’s failure to treat him in a community setting violates his right under the Americans with Disabilities Act, 42 U.S.C. § 12132 et. seq. ("ADA"), to receive Medicaid services in the most integrated setting appropriate to his medical needs. Defendants assert that the ADA does not authorize the relief Heartz seeks because it would force the state to “fundamentally alter” its program for providing Medicaid services to individuals with brain disorders. I evaluate the parties’ competing claims in ruling on Heartz’s request for a preliminary injunction. I. A. Plaintiff's Physical Condition Heartz has multiple sclerosis (“MS”), an acquired brain disorder. The symptoms associated with MS vary from person to person and generally worsen over time. Heartz has lost the use of his legs and has only limited use of his arms and hands. He uses a wheelchair and requires two aides and a mechanical lift to move him in and out of bed. He needs assistance with all of his daily activities, including feeding, grooming, and personal hygiene. His body temperature, nutrition, skin integrity, and bowel movements must be monitored. He has a chronic superpubic catheter that requires irrigation and 24-hour supervision. Heartz also suffers from depression and certain cognitive limitations. His memory is impaired, although he still occasionally recognizes friends and family. His condition is unlikely to improve.

Heartz lives in a nursing home in Concord, New Hampshire. He receives all necessary medical care and treatment and shares a small semi-private room with another person. He pays a portion of his care costs and the remaining costs are paid by Medicaid. On May 1 9 , 1998, the Merrimack County Probate Court found Heartz incompetent and appointed his brother, Robert Heartz, to serve as his legal guardian. The parties agree that a program could be developed to allow Heartz to receive treatment in a community

setting, although the cost of such a program remains in dispute.

B. The Medicaid Program

Medicaid is the primary federal program for providing

medical care to the poor. States that elect to participate in

the program initially pay the entire cost of services provided

under the program but later obtain partial reimbursement from the

federal government. Participating states must submit a “State

Plan” to the Secretary of the Health Care Financing Adminis-

tration (“HCFA”) demonstrating compliance with the Medicaid Act.

See 42 U.S.C. § 1396a.

The Medicaid Act identifies certain medical services that a

participating state must provide to eligible individuals and

lists other elective services. See 42 U.S.C. § 1396a(a)(10)(A);

see also 42 C.F.R. §§ 440.210(b), 440.220(a)(3). Among the

services that a participating state must provide are “home health

services.” 42 U.S.C. § 1396a(a)(10)(D). These services “are

provided to a recipient at his place of residence . . . on his

physician’s orders as part of a written plan of care.” 42 C.F.R.

§ 440.70(a). They include: (1) part-time or intermittent nursing

services; (2) home health aide services; and (3) medical

-3- supplies, equipment, and appliances. 42 C.F.R. § 440.70(b).

A state may also elect to include physical therapy, occupational

therapy, and speech pathology services as home health services.

§ 440.70(b)(4). The Medicaid Act draws a distinction between

“home health services,” which a state must make available to

qualifying individuals, and “home and community-based services,”

which ordinarily cannot be paid for with Medicaid funds. See 42

U.S.C. 1396n(c); 42 C.F.R. § 440.180. Home and community-based

services include a variety of services that otherwise are not

covered by Medicaid but which a recipient may need to avoid

institutionalization such a s : (1) case management services; (2)

homemaker services; (3) home health aide services; (4) personal

care services; (5) adult day health services;(6) habilitation

services; (7) respite care services; and (8) day treatment and

other partial hospitalization services. See 42 C.F.R. § 440.180.

The parties agree that Heartz requires home and community-based

care services in order to move from the nursing home into the

community.

-4- The Medicaid Act also imposes “state-wideness” and

“comparability” requirements on services provided pursuant to a

state plan. In other words, a state’s Medicaid plan must provide

that services provided by the plan “shall be in effect in all

political subdivisions of the state,” 42 U.S.C. §1396a(a)(1), and

“shall not be less in amount, duration, or scope than the medical

assistance made available to any other such individual.” 42

U.S.C. § 1396a(a)(10)(B)(i). These requirements prevent a

participating state from providing Medicaid benefits to a single

individual or to a group of individuals without offering

comparable benefits to all eligible individuals within the state.

C. Medicaid Waiver Programs

The Medicaid Act authorizes the Secretary of HCFA to waive

the Act’s requirements in specified circumstances to permit

states to “try new or different approaches to efficient and cost-

effective delivery of health care services, or to adapt their

programs to the special needs of particular groups or

recipients.” 42 C.F.R. § 430.25(b). Specifically, the Act

authorizes the Secretary to issue waivers for programs providing

home and community-based care to individuals who otherwise would

-5- require institutionalization. See 42 U.S.C. § 1396n(c); 42

C.F.R. § 441.300 et seq. To obtain the Secretary’s approval for

a home and community-based care waiver, the state seeking the

waiver must demonstrate that its average per capita expenditures

for persons receiving benefits under the waiver do not exceed the

average estimated per capita cost of providing Medicaid services

to the same group of individuals in an institutional setting.

See 42 U.S.C. § 1396n

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