NSCH Rural Health Clinic v. Drew Snyder, in his Official Capacity as Executive Director of the Division of Medicaid, and the Division of Medicaid, Office of the Governor, State of Mississippi

CourtCourt of Appeals of Mississippi
DecidedOctober 6, 2020
DocketNO. 2019-CC-00960-COA
StatusPublished

This text of NSCH Rural Health Clinic v. Drew Snyder, in his Official Capacity as Executive Director of the Division of Medicaid, and the Division of Medicaid, Office of the Governor, State of Mississippi (NSCH Rural Health Clinic v. Drew Snyder, in his Official Capacity as Executive Director of the Division of Medicaid, and the Division of Medicaid, Office of the Governor, State of Mississippi) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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NSCH Rural Health Clinic v. Drew Snyder, in his Official Capacity as Executive Director of the Division of Medicaid, and the Division of Medicaid, Office of the Governor, State of Mississippi, (Mich. Ct. App. 2020).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2019-CC-00960-COA

NSCH RURAL HEALTH CLINIC APPELLANT

v.

DREW SNYDER, IN HIS OFFICIAL CAPACITY APPELLEES AS EXECUTIVE DIRECTOR OF THE DIVISION OF MEDICAID, AND THE DIVISION OF MEDICAID, OFFICE OF THE GOVERNOR, STATE OF MISSISSIPPI

DATE OF JUDGMENT: 06/06/2019 TRIAL JUDGE: HON. J. DEWAYNE THOMAS COURT FROM WHICH APPEALED HINDS COUNTY CHANCERY COURT, FIRST JUDICIAL DISTRICT ATTORNEYS FOR APPELLANT: CRANE D. KIPP GRAFTON ERIC BRAGG ATTORNEYS FOR APPELLEES: JANET McMURTRAY SAMUEL PHILIP GOFF NATURE OF THE CASE: CIVIL - STATE BOARDS AND AGENCIES DISPOSITION: AFFIRMED - 10/06/2020 MOTION FOR REHEARING FILED: MANDATE ISSUED:

BEFORE WILSON, P.J., LAWRENCE AND McCARTY, JJ.

LAWRENCE, J., FOR THE COURT:

¶1. On October 10, 2017, NSCH Rural Health Clinic (North Sunflower) requested an

administrative hearing after the Mississippi Division of Medicaid (DOM) suspended

reimbursement payments for medical and dental services provided to Medicaid beneficiaries.

The services were suspended as a result of an ongoing investigation of potential fraud. The

DOM approved the administrative hearing but limited its scope to the sole issue of whether

good cause existed to not suspend or partially suspend such payments. On January 24, 2018, the hearing officer issued a recommendation to affirm the suspension of reimbursement

payments to North Sunflower. The DOM’s executive director adopted the hearing officer’s

recommendation on February 9, 2018. North Sunflower appealed the DOM’s decision to the

Hinds County Chancery Court.

¶2. On June 6, 2019, the chancery court entered its final judgment, dismissing North

Sunflower’s appeal and affirming the DOM’s decision. Aggrieved by the chancery court’s

decision, North Sunflower appealed. Finding no error, we affirm.

FACTS AND PROCEDURAL HISTORY

¶3. North Sunflower was a rural health care provider located in Ruleville, Mississippi,

which provided medical, dental, vision, and mental health care services to Medicaid

beneficiaries throughout the Mississippi Delta. North Sunflower’s clinic provided a wide

spectrum of services, offered extended hours of operation to the community, and accepted

walk-in patients. In conjunction with the clinic, North Sunflower also offered two offsite

outreach programs that provided services to surrounding communities for their medical and

dental needs. These outreach programs included (1) a dental outreach program that provided

dental services to nursing home residents at their respective facilities and (2) a school-

outreach program that provided “early and periodic screening and diagnostic treatment”

(EPSDT) as well as inoculations in schools and head-start program facilities throughout the

delta. Both dental and vision screenings were offered through the school-outreach program.

In 2012, the DOM approved the outreach programs to receive reimbursements for services

provided to Medicaid beneficiaries at the offsite locations.

2 ¶4. In 2017, the DOM received notice of allegations of fraud within North Sunflower’s

dental outreach program and more specifically, fraudulent billing under the primary code for

dental evaluations of nursing home patients.1 Pursuant to state and federal regulations, the

DOM referred the allegations of fraud to the Medicaid Fraud Control Unit (MFCU) at the

Mississippi Attorney General’s Office for further criminal investigation. Around that same

time, the DOM received notice of additional allegations of fraud within North Sunflower’s

school outreach program. On August 30, 2017, the DOM sent a letter to North Sunflower

providing notice that Medicaid reimbursements for the dental outreach program were being

suspended pending the results of the criminal investigation. On September 8, 2017, the

DOM sent North Sunflower an additional letter stating that it was suspending all Medicaid

reimbursements including reimbursements to the dental outreach program, the school-

outreach program, and the Ruleville clinic.

¶5. On October 10, 2017, North Sunflower requested an administrative hearing regarding

the suspension. On October 25, 2017, the DOM approved North Sunflower’s request for an

administrative hearing; however, the scope of the hearing was limited to a determination if

there was good cause to lift or limit the suspension. 23 Miss. Admin. Code Pt. 305, R. 1.2(E)

(adopted Nov. 1, 2016). No testimony or evidence was allowed pertaining to the substantive

facts regarding the credibility of the underlying allegations of fraud that led to the

suspension.

¶6. On November 16, 2017, an administrative hearing took place before hearing officer

1 “D0140” was the primary code for nursing home patient’s dental evaluations.

3 James Bell. At the administrative hearing, North Sunflower was given the opportunity to

present evidence to support its position that good cause existed to lift or limit the imposed

suspension. North Sunflower argued that the continued implementation of the suspension

would have an adverse effect on Medicaid beneficiaries’ access to necessary medical and

dental services that North Sunflower previously provided. Further, North Sunflower

attempted to offer evidence regarding the lack of credibility of the initial allegations of fraud;

however, after objection, it was not allowed to do so. Within its brief, North Sunflower

alleged that “though it had not been confirmed,” the company suspected that a former

employee was responsible for fraudulent billing and that her actions were potentially the

basis for the suspension. North Sunflower claimed that the fraudulent billing took place

without its knowledge or consent. But this evidence was not allowed or considered at the

administrative hearing. The DOM provided testimony that there would be no adverse effect

on Medicaid beneficiaries as a result of the suspension because there were alternate medical

and dental providers that offered the same types of services offered by North Sunflower.

After the administrative hearing, on December 11, 2017, the DOM lifted the suspension as

to the Ruleville clinic only. On January 24, 2018, hearing officer Bell issued his

recommendation to affirm the remaining suspension of reimbursement payments to North

Sunflower’s dental outreach program and school outreach program. On February 9, 2018,

the executive director of the DOM adopted the hearing officer’s recommendation and

affirmed the remaining suspensions.

¶7. On April 3, 2018, North Sunflower filed its notice of appeal in the Hinds County

4 Chancery Court. After oral and written argument from North Sunflower and the DOM, on

June 6, 2019, the chancery court entered its final judgment of dismissal, which affirmed the

DOM’s decision and dismissed all of North Sunflower’s claims. North Sunflower appealed.

STANDARD OF REVIEW

¶8. “In reviewing decisions of administrative agencies, this court will entertain the appeal

only to determine: whether or not the order of the administrative agency (1) was unsupported

by substantial evidence, (2) was arbitrary and capricious, (3) was beyond the power of

administrative agency to make, or (4) violated some statutory or constitutional right of the

complaining party,” Elec. Data Sys. Corp. v. Miss. Div. of Medicaid, 853 So. 2d 1192, 1202

(¶30) (Miss. 2013) (citing Mainstream Sav.

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NSCH Rural Health Clinic v. Drew Snyder, in his Official Capacity as Executive Director of the Division of Medicaid, and the Division of Medicaid, Office of the Governor, State of Mississippi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nsch-rural-health-clinic-v-drew-snyder-in-his-official-capacity-as-missctapp-2020.