Jacobs v. Massachusetts Division of Medical Assistance

CourtMassachusetts Appeals Court
DecidedApril 10, 2020
DocketAC 17-P-203
StatusPublished

This text of Jacobs v. Massachusetts Division of Medical Assistance (Jacobs v. Massachusetts Division of Medical Assistance) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jacobs v. Massachusetts Division of Medical Assistance, (Mass. Ct. App. 2020).

Opinion

NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports. If you find a typographical error or other formal error, please notify the Reporter of Decisions, Supreme Judicial Court, John Adams Courthouse, 1 Pemberton Square, Suite 2500, Boston, MA, 02108-1750; (617) 557- 1030; SJCReporter@sjc.state.ma.us

17-P-203 Appeals Court

WALTER H. JACOBS vs. MASSACHUSETTS DIVISION OF MEDICAL ASSISTANCE.

No. 17-P-203.

Suffolk. November 1, 2019. - April 10, 2020.

Present: Agnes, Sullivan, & Blake, JJ.

MassHealth. Medicaid. Division of Medical Assistance. Administrative Law, Hearing, Judicial review, Substantial evidence, Evidence. Due Process of Law, Administrative hearing.

Civil action commenced in the Superior Court Department on September 30, 2009.

The case was heard by Paul D. Wilson, J., on a motion for judgment on the pleadings.

Walter H. Jacobs, pro se. Cassandra Bolanos, Assistant Attorney General, for the defendant.

AGNES, J. This case concerns the treatment of patients who

receive medical benefits through the Massachusetts Medicaid 2

program known as MassHealth,1 and the requirements that

physicians must follow to be paid for services provided to those

patients. The plaintiff, Walter H. Jacobs, was a primary care

physician who billed MassHealth for services that he claimed to

have provided to MassHealth patients. MassHealth, after

conducting a required peer review of Jacobs's records, found

that he had repeatedly violated quality of care, record-keeping,

and billing standards. Jacobs unsuccessfully challenged those

findings during an administrative hearing and then sought review

of the administrative decision in the Superior Court. For the

reasons that follow, we affirm the judgment entered in the

Superior Court upholding the administrative decision.

Background. MassHealth, as a State Medicaid program,

covers medical expenses for certain individuals who would be

otherwise unable to afford necessary medical care. See Daley v.

Secretary of the Executive Office of Health & Human Servs., 477

Mass. 188, 189 (2017). While State Medicaid programs are run in

cooperation with the Federal government, MassHealth is a major

expenditure for Massachusetts, which finances a significant

portion of the benefits on its own. See id. at 189-190.

1 The defendant, the Massachusetts division of medical assistance, which is part of the Executive Office of Health and Human Services, administers MassHealth. See G. L. c. 118E, § 1. We refer to both the division of medical assistance and the program it administers as MassHealth. 3

Physicians who participate in the program and seek payment for

services provided to MassHealth patients therefore must comply

with a variety of billing regulations that require, among other

things, that physicians maintain "adequate documentation to

substantiate the provision of services payable under

MassHealth." 130 Code Mass. Regs. § 450.205(A) (2017).

On May 9, 2003, MassHealth notified Jacobs that, as

required by Federal and State law, it had contracted with an

entity referred to as MassPRO to conduct a "peer review of

services rendered by providers to MassHealth members."2 The

purpose of the review, as described by the notice sent to

Jacobs, was "to determine whether the services provided were

medically necessary, appropriate and of a quality that meets

professionally recognized standards of care." On May 14, 2003,

MassPRO contacted Jacobs and requested "copies of any and all

initial evaluations; history and physical exams; medical

records; appointment books; laboratory and diagnostic reports

and any and all other pertinent information for the [twenty-five

patients] listed on the attached listings for services provided

2 Federal regulations require any State that participates in Medicaid to "implement a statewide surveillance and utilization control program that . . . [s]afeguards against unnecessary or inappropriate use of Medicaid services and against excess payments." 42 C.F.R. § 456.3(a). State law requires MassHealth to "verify the accuracy of bills submitted . . . through the application of statistical sampling methods." G. L. c. 118E, § 38. 4

during the period of January 1, 2002 through December 31, 2002."

Upon receipt of Jacobs's records, MassPRO conducted its review

and then sent a draft report to MassHealth, which further

reviewed a random sample of eight MassHealth patients from

Jacobs's records.

Following the 2003-2004 review process, MassHealth sent an

initial notice to Jacobs citing more than 900 quality of care,

record-keeping, and billing violations across 371 office visits.

MassHealth suspended Jacobs from participating in MassHealth for

two years, effective immediately. Jacobs objected to the

initial notice. In 2005, after further review, MassHealth sent

two final notices to Jacobs. These notices confirmed the vast

majority of the violations that were identified in the initial

notice, while also citing additional violations.3 MassHealth

notified Jacobs of the violations and sought reimbursement in

the amount of $127,794.86.

A twenty-eight day administrative hearing followed in 2007

and 2008, during which MassHealth relied in large part on the

expert testimony of Jerome D. Siegel, a board-certified

physician who was also a MassPRO reviewer. Dr. George Abraham,

a board-certified physician, and Richard Hamilton, a managing

3 The initial final notice failed to address six violations that Jacobs had appealed. The amended final notice addressed the six additional violations. 5

partner at an accounting and auditing firm that specialized in

medical records review, testified for Jacobs. Jacobs also

testified on his own behalf. The hearing officer, who had also

reviewed the voluminous pages of exhibits, thereafter issued a

463-page decision containing specific findings with respect to

every office visit that served as the basis for one of the

violations listed in the amended final notice.

We summarize the facts as found by the hearing officer.4 As

to the quality of care violations, Jacobs's expert, Dr. Abraham,

testified that the primary determinant in assessing quality of

care was the result of that care, that is, whether the patient

died or suffered other detrimental effects. The hearing officer

did not credit this testimony and instead credited Dr. Siegel's

testimony that quality of care should be determined by the

information contained in Jacobs's records. Those records showed

Jacobs's consistent failure, among other concerning practices,

to document vital signs and the need for prescribed medications.

For example, regarding a woman who was seven months pregnant,

the hearing officer noted that "it is difficult to fathom a

definition of quality of care that does not include documenting

4 In his brief, Jacobs does not argue that any of the facts found in that decision were not supported by substantial evidence. While Jacobs suggested otherwise during oral argument, the issue has been waived. See Santos v. U.S. Bank Nat'l Ass'n, 89 Mass. App Ct. 687, 700 n.14 (2016). 6

blood pressure . . . to rule out pre-eclampsia." The hearing

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