Maine Care Servs., Inc v. Dep't of Human Servs.

CourtSuperior Court of Maine
DecidedSeptember 12, 2001
DocketCUMap-00-076
StatusUnpublished

This text of Maine Care Servs., Inc v. Dep't of Human Servs. (Maine Care Servs., Inc v. Dep't of Human Servs.) 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.

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Maine Care Servs., Inc v. Dep't of Human Servs., (Me. Super. Ct. 2001).

Opinion

STATE OF MAINE Sue

“Littg epi, HAIN SUPERIOR COURT CUMBERLAND, ss Clea.

-. I La oy ra aS A AO, 3 CIVIL ACTION S OFFIC EDOCKET NO. AP-00-076

Ser {2

Maine Care Services, Inc., 3 44 A Q [ Petitioner

Vv. DECISION AND ORDER

Department of Human Services,

Respondent

Petitioner Maine Care Services, Inc. (MCS) was a “sponsoring organization” under the Child and Adult Care Food Program (CACFP). On 3/24/99, the Department of Human Services (DHS) informed MCS that it was “seriously deficient” and that it had until 5/24/99 to respond to “Requirements for Corrective Action.” DHS Ex. 2; see 7 C.ER. § 226.6(c) (2001). On 5/24/99, MCS wrote to DHS and stated that it had substantially complied with the requested corrective action. MCS Ex. 74. On 7/26/99, DHS sent MCS a notice of termination from participation in the Child and Adult Food Care Program based on MC$’s failure to comply with the corrective action requirements. DHS Ex. 4

MCS appealed the termination and a hearing was held. Me. Dep't of Hum. Servs. Admin. Hearing Reg. 10 144 001 § VI(B) (February 7, 1996). The Hearing Officer recommended that DHS reverse its termination of MCS. Record Ex. B. DHS objected to the recommended decision. Record Ex. C. On 8/14/ 00, the DHS Commissioner issued a final decision and determined that DHS correctly

terminated MCS. Record Ex. E. MCS appeals that decision. See MLR. Civ. P. 80C; 5 M.R.S.A. § 11007 (1989). MCS argues the following:

(1) the Hearing Officer’s decision is the final decision in this matter; (2) the Commissioner’s decision was made upon unlawful procedure and is a violation of due process; (3) the Commissioner received ex parte communications; (4) the Commissioner’s conclusions of law are not supported by the findings of fact.

For the following reasons, the Commissioner’s decision is VACATED and the case is

REMANDED.

1. HEARING OFFICER DECISION

Upon MCS’s request for a hearing, the Commissioner referred this matter to a hearing officer pursuant to DHS Administrative Hearing Regulations. See Me. Dep’t of Hum. Servs. Admin. Hearing Reg. 10 144 001 §§ IV(O) & V(A) & (D), VI(A) (February 7, 1996). The Commissioner requested that the hearing officer make a recommended decision and reserved final decision making authority to himself. See id. § VII(B)(5). MCS objected to this procedure after the hearing was held and the Hearing Officer’s decision was issued.

The current. Administrative Hearing Regulation became effective in February, 1996 and provides that its procedures supersede and replace any inconsistent or conflicting regulations unless required by state or federal law or federal regulations. See id. § I, 7 3. Neither Maine nor federal law requires that a

hearing officer’s recommenced decision be the final decision. See 5 M.R.S.A. § 9062(1) (1989); 7 C.E.R. § 226.6(k) (2001); Me. Dep’t of Hum. Servs. Admin. Hearing Reg. 10 144 001 §§ IV(O), V(A) & (D), VII(B)(5) (February 7, 1996). Because DHS has established administrative appeal procedures; CACFP appeal procedures do not apply. See 7 C.F.R. § 226.6(k). Further MCS waived this issue by not objecting to the order of reference. MCS objected by letter dated 5/30/00, over three months after the Hearing Officer’s 2/4/00 decision, which followed several days of testimony. See

Record Exs. B & D; New England Whitewater Ctr.,.Inc. v. Dep’t of Inland Fisheries

and Wildlife, 550 A.2d 56, 58 (Me. 1988) (Rule 80C plaintiffs expected to raise issues before agency in order to preserve issues for appeal). 2. COMMISSIONER’S DECISION MADE UPON AWFUL EDURE AND VIOLATES DUE PROCESS The petitioner argues that the Commissioner’s decision was unlawful because he did not hear the evidence in this case. See Petitioner's Mem. at 9. That is not required. An agency can authorize a person to preside over a hearing. See 5

M.RS.A. § 9062(1) (1989); Me. Dep’t of Hum. Servs. Admin. Hearing Reg. 10 144 001

§ VII(B)(5); Greely v. Comm’r, Dept of Human Servs.; 2000 ME 56, 7, 748 A.2d 472, A74 (statute authorizes agency employee to preside over administrative hearing).

Sufficient review of evidence and argument is required. See Davric Maine Corp. v.

Maine Harness Racing Comm’n, 1999 ME 99, {16, 732 A.2d 289, 295 (where

Legislature provides, administrative agency can delegate powers to subordinate

officer).

3. EX PARTE COMMUNICATIONS

The Commissioner consulted with and received advice from the Chief Administrative Hearing Officer and Deputy Commissioner. The record does not show that either participated in the proceeding as an advocate. See 5 MLR.S.A. § 9055(2)(A) & (B) (1989) (advice from members of agency staff who did not and will not participate in adjudicatory proceeding in advocate capacity is not prohibited); Me. Dep’t of Hum. Servs. Admin. Hearing Reg. 10 144 001 § V(B)(2) (February 7, 1996).

The Commissioner also received a letter from Francis Zorn, Administrator for the Northeast Region of the Food and Nutrition Service of the United States Department of Agriculture. Record Ex. C. A copy of the letter was sent to counsel for MCS and DHS, although not by Francis Zorn. Because counsel received the letter and had the opportunity to respond, the Zorn letter cannot be considered an ex parte communication. See Me. Dep’t of Hum. Servs. Admin. Hearing Reg. 10 144 001 § V(B)(1); Bickerman Letter dated 2/16/00; Whiting Letter dated 2/23/00; Bickerman Letter dated 2/25/00.

4, MMISSIONER’ INCLUSIONS OF LAW

Every Reasonable Opportunity

The petitioner argues that the Commissioner applied incorrectly the “every reasonable opportunity” requirement in the federal regulations. A state agency shall afford an institution every reasonable opportunity to correct problems before terminating the institution for being seriously deficient.” 7 C.F.R. § 226.6(c). The federal regulations do not define the term “every reasonable opportunity”. See ~ Record Ex. E at 1;7 C.E.R. § 226.2 (2001).

The Commissioner expressly rejected the meaning of “every reasonable opportunity” advanced by the United States Department of Agriculture and the CACFP. Record Ex. E at 1. He determined that he would use common sense, fairness, and a review of relevant parts of the record to determine whether MCS was given every reasonable opportunity before its termination. See Record Ex. E at 2. The Commissioner stated that he was the ultimate interpreter of policy for the Department and that the courts give deference to that interpretation. See Record _ Ex. E at 1; CWCO, Inc. v. Superintendent of iIns., 1997 ME 226, ¥ 6, 703 A.2d 1258, 1261 (special deference due when issues are within scope of agency’s technical expertise). DHS gave MCS 60 days to respond to requirements for corrective action. See

DHS Ex. 2; HO Ex. 4; 7 CER. § 226.6(c); Arkansas Dep’t of Human Servs. v. Arkansas

Child Care Consultants, Inc., 889 S.W.2d 24, 25 (1994) (sponsor given 50 days, not 15 days provided by regulation). MCS was expected to correct the deficiencies within the time frame provided and not simply to develop a plan for correction of the deficiencies. See DHS Ex. 2, DHS provided a “Corrective Action” for each deficiency. See DHS Ex. 2, Enclosure 2.

Considerable deference is given to an agency’s interpretation of its own internal rules, regulations, and procedures.

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