Palian v. Maine Department of Health & Human Services

CourtSuperior Court of Maine
DecidedMay 17, 2019
DocketKENap-18-49
StatusUnpublished

This text of Palian v. Maine Department of Health & Human Services (Palian v. Maine Department of Health & Human Services) 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
Palian v. Maine Department of Health & Human Services, (Me. Super. Ct. 2019).

Opinion

STATE OF MAINE SUPERIOR COURT KENNEBEC, ss CIVIL ACTION DOCKET NO. AP-18-49

CHARLES PALIAN, DMD, ·

Petitioner

V. DECISION AND ORDER

MAINE DEPARTMENT OF HEALTH & HUMAN SERVICES,

Respondent

Before the court is Petitioner Charles Palian, DMD's Appeal of Final Agency

Action pursuant to M.R.Civ.P. 80C against the Maine Department of Health and

Human Services. After reviewing the Record, the parties' filings, and considering

the parties' arguments at hearing, the court finds that Petitioner's Rule 80C appeal

must be denied and the Respondent's decision should be affirmed.

I. Background

Petitioner Dr. Palian was an .oral surgeon and MaineCare provider in

Lewiston, Maine until his retirement in 2013. (R. 1074.) As a MaineCare provider,

Dr. Palian was contractually obligated to adhere to MaineCare rules via a Provider

Agreement, signed September 11, 2009. (R. 336.) In December, 2014, Valerie

Hooper, an employee of the Maine Department of Health and Human Services

Program Integrity Unit (the "Department") sent a request for information to Dr.

1 Palian for a post-payment review or audit. (R. 458, 1149.) Ms. Hooper performed

the post-payment review, or audit, selecting a~ random 100 of Dr. Palian's patients

for which Dr. Palian submitted claims from September 1, 2010, through December

31, 2013. (R. 1149-50.)

On October 2, 2015, the Department issued Dr. Palian a Notice of Violation

reporting that for the 100 randomly-selected patients reviewed during the September

1, 2010 - December 31, 2013 time period, the Department sought $189,770.08 as a

recoupment for various violations .1 (R. 32.) The Notice of Violation alleged that

Dr. Palian had violated the MaineCare Benefits Manual through: 1) improper or

incomplete documentation for interpreter services, radio graphs, anesthesia recovery

times, tooth numbers for tooth extractions and dates of service; 2) improper coding

for non-emergency hospital procedures; 3) improper coding for Versed, Fentanyl,

Ketamine, Propofol, and Valium; 4) billing for drugs above acquisition cost; 5)

duplicate payments, payments for services covered through primary insurance, or

payments not billed to primary insurance; 6) improper coding for comprehensive

oral evaluation; and 7) improper coding for alveoplasty when less than four teeth per

quadrant were extracted. (R. 32-34.)

'The Department found that the violations constituted a 14.89% error rate, which it multiplied by the entire reimbursement amount for the period audited, i.e., $1,274,480.03, for a total recoupment amount of $189,770.08. (R. 32-34.)

2 Dr. Palian timely requested an informal review of the Department's Notice of

Violation, arguing: 1) documentation for two patients' procedures was provided; 2)

the code used for non-emergency hospital procedures was correctly used because a

hospital qualifies as an "institution" under the American Dental Association's Dental

Procedure Codes; 3) claims for improper documentation for anesthesia recovery

times misinterpreted the code requirements; 4) adequate radio graph documentation

was provided; 5) claims for overpayments for alveoplasty misinterpreted the code

requirements; 6) individual claims for overpayments were unfounded; and, 7) claims

for overpayments on drug acquisition costs misinterpreted the code requirements.

(R. 83.) Furthermore, Dr. Palian argued that the Department failed to pay him for

multiple claims submitted for reimbursement. (R. 83 .)

On August 9, 2016, Herb Downs, Director of the Department's Division of

Audit, issued a Final Informal Review Decision, revising the overpayment

calculation amount to $147,329.89. (R. 104.) Ms. Hooper drafted the decision and

provided Mr. Downs with the audit materials, according to standard procedure. (R.

1434-35.) The Final Informal Review Decision overturned the finding of an

overpayment on 33 line-items and reduced the finding of an overpayment to a 20%

sanction for inadequate documentation, overpayments for drug acquisition costs,

supplemental charges for services billed under codes the Department deemed

incorrect, and anesthesia recovery time overcharges. (R. 104.)

3 Dr. Palian timely requested an administrative hearing. (R. 151.) On July 17,

2017 and again on January 9, 2018, the Department held an administrative hearing

before Hearing Officer Richard Thackeray. (R. 1122, 1325.) After the hearing, the

Department reduced its demand to $116,852 .05, revising a 100% sanction for lack

of documentation of anesthesia recovery times to a 20% sanction. (R. 375 .) On

June 5, 2018, Hearing Officer Thackeray issued an Administrative Hearing

Recommended Decision, finding that the Department correctly established and

maintained a recoupment claim against Dr. Pali an for $116,852.05. (R. 107 6 .) In

response to Dr. Palian' s other arguments, the Hearing Officer concluded that "the

Department did not violate Dr. Palian' s procedural rights by virtue of Ms. Hooper

assisting Mr. Downs during the Final Informal Review." (R. 1078.) The Hearing

Officer found that the Department should not be equitably estopped from

maintaining a recoupment claim against Dr. Palian. (R. 1090.) Lastly, the Hearing

Officer determined that Dr. Palian did not preserve for appeal the argument that the

Department abused its discretion (or failed to exercise discretion at all) by imposing

the maximum penalty of 20% for improperly documented claims. (R. 1090.)

Dr. Palian filed a Responses and Exceptions to the Recommendations of the

Hearing Officer on June 19, 2018. (R. 1094.) On July 3, 2018, Commissioner

Ricker Hamilton issued the Final Decision adopting the Recommended Decision.

4 (R. 1121.) Dr. Palian timely filed this Rule 80C appeal. Oral argument was held on

April 23, 2019.

II. Standard of Review

When the decision of an administrative agency is challenged on appeal, the

court may reverse or modify the decision if the administrative findings, inferences,

conclusions or decisions are:

1) In violation of constitutional or statutory provisions; 2) In excess of the statutory authority of the agency; 3) Made upon unlawful procedure; 4) Affected by bias or error of law; 5) Unsupported by substantial evidence on the whole record; or 6) Arbitrary or capricious or characterized by abuse of discretion .

5 M.R.S. § 11007(4) (2018). The court will sustain the administrative decision if,

"on the basis of the entire record before it, the agency could have fairly and

reasonably found the facts as it did." Seider v. Bd. of Examiners of Psychologists,

2000 ME 206, ~ 9, 7 62 A .2d 5 51. The court will affirm the findings of fact if there

is any competent evidence in the record to support them, even if the record contains

other inconsistent or contrary evidence. Bankers life & Cas. Co. v. Superintendent

of Ins., 2013 ME 7, ~ 16, 60 A.3d 1272. The party seeking to vacate the agency's

decision bears the burden of proving that no competent evidence exists to support

the decision. Seider, at~ 9.

5 III. Discussion

The Department's decision is affirmed on the following grounds: (1) the

Department's claims are not barred by equitable estoppel; (2) the Informal Review

was conducted by a Department representative who was not involved in the decision

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Related

Department of Health & Human Services v. Pelletier
2009 ME 11 (Supreme Judicial Court of Maine, 2009)
Downeast Energy Corp. v. Fund Insurance Review Board
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Seider v. Board of Examiners of Psychologists
2000 ME 206 (Supreme Judicial Court of Maine, 2000)
Department of Human Services v. Bell
1998 ME 123 (Supreme Judicial Court of Maine, 1998)
Bankers Life and Casualty Company v. Superintendent of Insurance
2013 ME 7 (Supreme Judicial Court of Maine, 2013)

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