In Re Appeal of K.M.

2024 VT 63
CourtSupreme Court of Vermont
DecidedOctober 11, 2024
Docket24-AP-027
StatusPublished
Cited by1 cases

This text of 2024 VT 63 (In Re Appeal of K.M.) is published on Counsel Stack Legal Research, covering Supreme Court of Vermont primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Appeal of K.M., 2024 VT 63 (Vt. 2024).

Opinion

NOTICE: This opinion is subject to motions for reargument under V.R.A.P. 40 as well as formal revision before publication in the Vermont Reports. Readers are requested to notify the Reporter of Decisions by email at: JUD.Reporter@vtcourts.gov or by mail at: Vermont Supreme Court, 109 State Street, Montpelier, Vermont 05609-0801, of any errors in order that corrections may be made before this opinion goes to press.

2024 VT 63

No. 24-AP-027

In re Appeal of K.M. Supreme Court

On Appeal from Human Services Board

September Term, 2024

Michael J. Donohue, Chairperson

Barbara W. Prine, Burlington, and Susan Garcia Nofi, Saint Johnsbury, Vermont Legal Aid, Inc., for Appellant.

Charity R. Clark, Attorney General, Montpelier, and Benjamin Chater, Assistant Attorney General, Waterbury, for Appellee Vermont Department of Disabilities, Aging and Independent Living.

PRESENT: Reiber, C.J., Eaton, Cohen and Waples, JJ., and Johnson, J. (Ret.), Specially Assigned

¶ 1. WAPLES, J. In this case, we consider whether the Human Services Board may

grant relief to a person with disabilities who is not receiving the services to which he is entitled.

Through Medicaid programs administered by the Department of Disabilities, Aging, and

Independent Living (DAIL), K.M. is supposed to receive more than thirty hours of support services

each week. Since March 2020, he has received no more than five hours of services each week.

K.M. petitioned the Board seeking an order directing DAIL to provide all the services to which he

is entitled. The Board dismissed his petition for failure to state a claim upon which relief can be granted. We reverse the Board’s dismissal of K.M.’s petition and remand to the Board for further

proceedings.

¶ 2. The following facts are drawn from the record and are undisputed for purposes of

this appeal. K.M. is an adult with numerous disabilities, including autism, obsessive-compulsive

disorder, a seizure disorder, and other conditions. For more than twenty years, he has received

Medicaid-funded home and community-based developmental disabilities services provided by

Washington County Mental Health Services (WCMHS). WCMHS is supposed to provide more

than thirty hours per week of community supports. Since March 2020, K.M. has received only

two-to-five hours of community supports each week. The reduction in services has caused K.M.

various negative health effects.

¶ 3. WCMHS is a member of Vermont Care Partners, a statewide network of sixteen

nonprofit community-based organizations that provide developmental disability services. The

agencies that comprise Vermont Care Partners collectively report their staffing shortages and

vacancies. The agencies report high staff vacancy and turnover rates for positions that provide

care. A study of that workforce in Vermont found that low wages contribute to departures from

the profession.

¶ 4. Though WCMHS is K.M.’s service provider, DAIL is ultimately responsible for all

Medicaid-funded developmental services in Vermont. 18 V.S.A. § 8723. DAIL allocates and

disburses Medicaid funds for the services, which are provided by designated agencies and

specialized services agencies. Id. § 8907. Medicaid is a cooperative federal-state program under

which states receive federal funds for state-administered Medicaid services in exchange for

compliance with the requirements of the Medicaid Act. See 42 U.S.C. §§ 1396 to 1396w-8; see

also Brisson v. Dep’t of Soc. Welfare, 167 Vt. 148, 150, 702 A.2d 405, 407 (1997).

¶ 5. The federal Medicaid Act requires that state Medicaid programs “provide that all

individuals wishing to make application for medical assistance under the plan shall have

2 opportunity to do so, and that such assistance shall be furnished with reasonable promptness to all

eligible individuals.” 42 U.S.C. § 1396a(a)(8). The statute defines “medical assistance” as

“payment of part or all of the cost of the following care and services or the care and services

themselves, or both.” Id. § 1396d(a) (emphasis added). Implementing regulations require the

designated state agency to: “(a) [f]urnish Medicaid promptly to beneficiaries without any delay

caused by the agency’s administrative procedures” and “(b) [c]ontinue to furnish Medicaid

regularly to all eligible individuals until they are found to be ineligible.” 42 C.F.R. § 435.930.

¶ 6. State law echoes the federal Medicaid requirements. DAIL must, “within the limits

of funds designated by the General Assembly for this purpose, ensure that community

services . . . are provided.” 18 V.S.A. § 8907(a). DAIL’s obligations extend to individual

recipients. “Any person with a developmental disability . . . shall be provided with . . . [s]ervices

and funding within the Department’s available resources in accordance with both the system of

care plan and the person’s . . . written plan of service.” Id. § 8726(c) (emphasis added). If a

recipient has a “claim for assistance, benefits, or services” that is “not acted upon with reasonable

promptness,” the Human Services Board must grant the recipient a fair hearing. 3 V.S.A.

§ 3091(a).

¶ 7. In this case, K.M. asked the Board to order DAIL to provide him with all the

services for which he is eligible under state and federal law with “reasonable promptness,” as

contemplated by 3 V.S.A. § 3091(a) and 42 U.S.C. § 1396a(a)(3). The Board concluded that his

request did not state a cognizable claim for relief because it was “too vague to inform the

Department as to the action to take in order to comply with an injunction.” It explained that “[a]n

order directing the Department to provide services when there is no staff available to perform them

falls short of informing the Department of what would be required for compliance.” The Board

also interpreted K.M.’s request as seeking an order commanding DAIL to “address either the

statewide staffing problem with the requisite urgency and/or the issue of Developmental Services

3 staff wages.” It found that “any determination made by the Board about the validity of DAIL’s

policy would not affect the level of services that [K.M.] received, so the Board could grant no

relief,” quoting Husrefovich v. Department of Aging & Independent Living, 2006 VT 17, ¶ 28,

179 Vt. 456, 898 A.2d 726. The Board therefore granted DAIL’s motion to dismiss K.M.’s

petition. K.M. appealed.

¶ 8. On appeal, K.M. argues that the Board erred in concluding that it lacked authority

to order DAIL to provide the benefits to which he is entitled. Whether the Board has the authority

to grant relief is a question of law that we review de novo. In re P.J., 2009 VT 5, ¶ 7, 185 Vt. 606,

969 A.2d 133 (mem.). On appeal from a dismissal for failure to state a claim upon which relief

can be granted, “we assume the truth of all factual allegations in the [petition] and accept all

reasonable inferences that may be derived from [the petitioner’s] pleadings.” In re Blow, 2013

VT 75, ¶ 8, 194 Vt. 416, 82 A.3d 554 (quotation omitted).

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