Houlton Regional Hospital v. Lambrew

CourtSuperior Court of Maine
DecidedSeptember 3, 2019
DocketAROap-19-01
StatusUnpublished

This text of Houlton Regional Hospital v. Lambrew (Houlton Regional Hospital v. Lambrew) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Houlton Regional Hospital v. Lambrew, (Me. Super. Ct. 2019).

Opinion

STATE OF MAINE SUPERIOR COURT AROOSTOOK, ss. CIVIL ACTION DOCKET NO. HOUSC-AP-19-01

HOULTON REGIONAL HOSPITAL ) ) Petitioner ) ) v. ) DECISION AND ORDER ) JEANNE LAMBREW, COMMISSIONER ,) MAINE DEPARTMENT OF HUMAN ) SERVICES, ) ) ) And ) ) MAINE DEPARMENT of HEALTH ) AND HUMAN SERVICES ) ) Respondent )

Pending before the Court is Houlton Regional Hospital's (the "Petitioner", and also

referred to as "HRH") appeal from the Final Decision issued on February 7, 2019 by the

Commissioner of the Maine Department of Human Services (the "Department"). More

specifically, HRH appeals the Commissioner's acceptance in toto the Hearing Officer's

Administrative Hearing Recommended Decision ("AHRD") and findings that (i) the Department

was permitted to rely upon the Centers for Medicare and Medicaid Services' ("CMS") Medicare

unit to determine whether HRH qualified for Electronic Health Record ("ERH") incentive

payments under the MaineCare HIT Incentive Payment Program; (ii) that HRH is not entitled

under the MaineCare Benefits Manual ("MBM") to an independent review by the Department as

to whether HRH complied with the specific MaineCare EHR/HIT Incentive Payment Program

requirements that were subject to CMS's audit; and (iii) that the Department correctly established

a recoupment claim in the amount of $344,644 against HRH based on the audit finding by CMS

I that HRH did not meet the Medicare HRH Incentive Program's requirements for the Program Year

2013. In this appeal HRH requests the court order the Department to conduct its own independent

review of CMS's audit based on its assertion that such an independent review is required under

the applicable regulations and the MaineCare Benefits Manual (MBM). The Department asserts

that the Department was entitled to rely upon the determination by CMS of HRH's failure to

comply with Meaningful Use Requirements, and that HRH, having appealed the issue through

CMS, is collaterally estopped from re-litigating the issue. The Department asks the

Commissioner's Final Decision be affirmed.

Oral argument was held telephonicaHy on August 28, 2019. Based upon the filings and

arguments, the court makes the following findings and decision.

STATEMENT OF FACTS•

1. HRH is an enrolled Medicare provider and participated as an "eligible hospital" in the Medicare Electronic Health Record ("EHR") Technology Incentive Program (the "CMS EHR Program") administered by the Centers for Medicare and Medicaid Services ("CMS"), for Program Year 2013, i.e., for the attestation period March 15, 2013 through June 15, 2013 (the "2013 Attestation Period").

2. HRH is an enrolled MaineCare provider (see Exhibit J-2) and also participated as an "eligible hospital" in the State Medicaid Health Information Technology Program administered by the Department (the "MaineCare HIT Program") in accordance with administrative rules set forth in the MaineCare Benefits Manual at 10-144 C.M.R. Chapter 10 I, Chapter I, Section 2, for Program Year 2013.

3. In connection with HRH's patiicipation in the CMS EHR Program and MaineCare HIT Program, HRH attested that it had adopted certified EHR technology ("CEHRT") that met all applicable regulatory requirements for such CERHT for Program Yeat· 2013.

, This Statement of Facts is from the Statement of Agreed-Upon Material Facts submitted by the parties in the appeal by HRH of the Depmtment's Final Informal Review Decision dated January 22, 2018. See H0-6 in Vol. I of the Certified Record; references to Exhibits has been edited to correlate with Joint Exhibits, which are in Vol. 2 of the Certified Record.

2 4. The Department developed a final "State Medicaid Health Information Technology Plan," dated May 12, 2011 (the "2011 SMHP") (Exhibit J-3), conditionally approved by CMS on April 28, 2011 (Exhibit J-4) and finally approved on June 23, 2011 (Exhibit J-5).

5. The Department's 2011 SMHP was subsequently revised by the Department in December 2015, Final v. 2.0 (the "2015 SMHP").

6. The Department promulgated administrative rules (the "MaineCare HIT Program Rules") under the Maine Administrative Procedures Act (the "APA") to implement the MaineCare HIT Program that became effective October 4, 2011, which rules were incorporated into the MaineCare Benefits Manual at 10-144 C.M.R. Chapter IOI, Section 2, "State Medicaid Health Information Technology Program" (the "October 2011 MaineCare HIT Program Rules"). See Exhibit J-6.

7. The October 2011 MaineCare HIT Program Rules were subsequently amended by the Department pursuant to rule-making under the APA in November 2014, and these amended Rules became effective on November 23, 2014.

8. The October 2011 HIT Program Rules were the rules in effect for HRH's Program Year 2013 and 2013 Attestation Period.

9. The version of 10-144 C.M.R. Chapter 101, Chapter I, Section I, of the MaineCare Benefits Manual that was in effect at the beginning of HRH Program Year 2013 and 2013 Attestation Period is identified in the record as Exhibit J-7, which also reflects amended rules that were incorporated under the APA on June 24, 2013.

10. HRH received a total of$307,168.84 in incentive payments from CMS for HRH's participation in the CMS EHR Program in Program Year 2013.

11. HRH received a total of $344,644 in incentive payments for HRH's participation in the Maine Care HIT Program in Program Year 2013. The incentive payments were transmitted by the Department but were comprised of I 00% federal funds.

12. In or around August 2014, CMS's auditor, Figliozzi & Company ("CMS's Auditor"), conducted an audit (the "CMS Audit") of HRH to determine "how HOULTON REGIONAL HOSPITAL demonstrated meaningful use of certified Electronic Health Record (EHR) technology in accordance with Section 13411 of the Health Information Technology for Economic and Clinical Health Act (HITECH Act)" for Program Year 2013.

13. On August 18, 2014, CMS's Auditor issued to HRH a "HITECH EHR Meaningful Use Audit Determination Letter" in which the Auditor determined that HRH did not meet the meaningful use criteria for Program Year 2013 based on the Auditor's finding that HRH "[flailed to demonstrate access to a CEHRT system." See Exhibit J-8.

3 14. On August 29, 2014, HRH requested that CMS's Auditor specify what, in the Auditor's determination, HRH's EHR system lacked or was missing that prevented HRH from demonstrating access to a CEHRT system. See Exhibit J-9.

15. On the same date, August 29, 2014, CMS's Auditor responded to HRH by stating that "[a]dditional documentation was supplied [by HRH] confirming that the interfaces for Menu Measures #8, #9, and #10 were not in place at any point during the attestation period." See Exhibit J-10.

16. On September 16, 2014, HRH submitted to CMS (i) additional documentation in support of HRH's position that it had demonstrated access to a CEHRT system, and (ii) an "Eligible Hospital Appeal Filing Request" appealing the CMS Auditor's HITECH EHR Meaningful Use Audit Determination Letter decision. See Exhibit J-11.

17. In a letter from CMS to HRH dated September 26, 2014, CMS denied HRH's Appeal, a decision that was "final and not subject to further appeal." See Exhibit J-12.

18. On March 31, 2016, the Department issued to HRH a Recoupment Notice letter notifying HRH of the Department's intent, based on the audit findings of the CMS Auditor, to recoup the $344,644 in incentive payments the Department had paid to HRH for HRH's participation in the MaineCare HIT Program for Program Year 2013. See Exhibit J-13.

19.

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Related

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534 A.2d 667 (Supreme Judicial Court of Maine, 1987)
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2000 ME 206 (Supreme Judicial Court of Maine, 2000)
State of Maine v. Andrew J. Legassie
2017 ME 202 (Supreme Judicial Court of Maine, 2017)
Carrier v. Secretary of State
2012 ME 142 (Supreme Judicial Court of Maine, 2012)

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