Professional Home Health Care v. Commonwealth of Kentucky Cabinet for Health and Family Services

CourtCourt of Appeals of Kentucky
DecidedApril 20, 2023
Docket2022 CA 000046
StatusUnknown

This text of Professional Home Health Care v. Commonwealth of Kentucky Cabinet for Health and Family Services (Professional Home Health Care v. Commonwealth of Kentucky Cabinet for Health and Family Services) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Professional Home Health Care v. Commonwealth of Kentucky Cabinet for Health and Family Services, (Ky. Ct. App. 2023).

Opinion

RENDERED: APRIL 21, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2022-CA-0046-MR

PROFESSIONAL HOME HEALTH CARE APPELLANT

APPEAL FROM FRANKLIN CIRCUIT COURT v. HONORABLE THOMAS D. WINGATE, JUDGE ACTION NO. 20-CI-00294

COMMONWEALTH OF KENTUCKY CABINET FOR HEALTH AND FAMILY SERVICES AND KENTUCKY DEPARTMENT FOR MEDICAID SERVICES APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: CETRULO, JONES, AND MCNEILL, JUDGES.

JONES, JUDGE: Professional Home Health Care (PHHC) appeals the Franklin

Circuit Court’s order affirming the final order of the Secretary of the Cabinet for

Health and Family Services (the Cabinet). The circuit court agreed with the Cabinet that PHHC had been overcompensated for certain Medicaid services and,

as a result, recoupment in the amount of $1,062,171 was appropriate. After a

thorough review of the record and the law, we affirm.

I. BACKGROUND

The Cabinet is the state agency authorized to administer Kentucky’s

Medicaid program under KRS1 205.520. PHHC “is a home health care agency that

provides in-home care services to Medicaid patients in rural counties in eastern

Kentucky through the Cabinet’s Home and Community Based Waiver (HCBW or

HCB Waiver) Program.” (Appellant’s Brief at 1.) The HCBW program is

designed to assist elderly or disabled individuals in such a way that they may live

as independently as possible in their communities rather than reside in a nursing

facility.

In 2009, the Cabinet amended the relevant regulation, 907 KAR2

1:170, to provide enhanced payments to providers for defined revenue code

services. Specifically, the amended version of 907 KAR 1:170, which went into

effect July 1, 2009, stated the Cabinet would pay “for a revenue code service

provided by a safety net provider a rate equal to the median rate of all local health

1 Kentucky Revised Statutes. 2 Kentucky Administrative Regulations.

-2- departments for the revenue code service.” 907 KAR 1:170 § 4(1).3 The same

regulation also defined “revenue code services” as “[a]n assessment, reassessment,

homemaking, personal care, respite, or attendant care service; or . . . a minor home

adaptation.” 907 KAR 1:170 § 1(19). Notably absent from the definition of

“revenue code services” was the provision of case management services,4 which

were noted as payable at a fixed upper rate limit specified in Section 2 of the

regulation.

Despite the language in the regulation, the Cabinet paid PHHC the

enhanced rate for case management services for several years afterward. However,

on May 2, 2016, the Cabinet informed PHHC that these payments were in error

because case management services were not eligible for the enhanced payments

assigned to revenue code services in 907 KAR 1:170 § 1(19). The Cabinet then

sought recoupment of the excess payments, as authorized by 907 KAR 1:671, for

three fiscal years: 2011 ($264,116), 2012 ($385,677), and 2013 ($412,378), for a

total of $1,062,171. PHHC appealed the recoupment determination to a hearing

officer, arguing that the recoupment was arbitrary after several years of payments,

3 907 KAR 1:170 was amended in 2016. The current version omits enhanced benefit payments as previously provided in Section 4, and it no longer defines revenue code services in Section 1. 4 According to the hearing officer’s recommended order, “Case management requires that a qualified individual be responsible for locating, coordinating and monitoring a group of services to be provided to a recipient. This involves reviewing the patient’s assessments, locating various providers that are able to meet a patient’s needs, and checking in at least monthly with the patient.” (Record (R.) at 10.)

-3- and that the omission of “case management” from the regulation was a drafting

error. PHHC also argued that individuals employed by the Cabinet represented

that case management services were reimbursable at the enhanced rate, and the

Cabinet should now be equitably estopped from recouping the excess payments.

Finally, PHHC argued that the equitable doctrine of laches should apply to prevent

the Cabinet from recoupment.

Following an administrative hearing held on June 19, 2018, the

hearing officer issued a recommended order upholding the Cabinet’s recoupment.

The hearing officer pointed out that administrative regulations in Kentucky enjoy a

rebuttable presumption of correctness, and that there was “no question” that the

regulation in this case was properly promulgated under KRS 13A. (Hearing

Officer’s Order at 12.) The hearing officer also pointed out that no public

comments were filed regarding the regulation, PHHC was fully aware of the

language in the regulation, and PHHC had ample opportunity to comment if it

thought “case management services” were inadvertently omitted from the

Regarding PHHC’s specific legal arguments, the hearing officer

submitted that the rules of construction for interpreting administrative regulations

are identical to those for interpreting statutes, and “a statute may not be interpreted

at variance with its stated language.” (Hearing Officer’s Order at 13 (citing

-4- Revenue Cabinet, Commonwealth v. Gaba, 885 S.W.2d 706, 708 (Ky. 1994))).

The hearing officer also found equitable estoppel was not warranted here because

it could be applied to government agencies only under a finding of “unique

circumstances” involving “exceptional and extraordinary equities.” (Hearing

Officer’s Order at 15 (citing Sebastian-Voor Properties, LLC v. Lexington-Fayette

Urban County Gov’t, 265 S.W.3d 190, 194 (Ky. 2008))). Finally, the hearing

officer declined to apply laches as relief, finding that PHHC did not offer any legal

support for the premise that laches was applicable against a government agency in

Kentucky, nor was there any apparent violation of a statute of limitations. The

Secretary of the Cabinet subsequently issued a final order adopting the

recommended order, and PHHC appealed the decision to the Franklin Circuit

Court. In a thorough ten-page opinion, the circuit court affirmed the Secretary’s

final order. This appeal followed.

II. ANALYSIS

We begin by noting our role as the reviewing court of an

administrative agency decision is relatively limited. “Judicial review of an agency

decision is limited to the determination of whether the decision was arbitrary, i.e.,

whether the action was taken in excess of granted powers, whether affected parties

were afforded procedural due process, and whether decisions were supported by

substantial evidence.” Sebastian-Voor, 265 S.W.3d at 195 (citation omitted).

-5- Pursuant to KRS 13B.150(2), a court sitting in review “shall not substitute its

judgment for that of the agency as to the weight of the evidence on questions of

fact.” However, “[w]hen a question of law arises out of an administrative hearing,

appellate review is conducted de novo.” Cabinet for Health and Family Services v.

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Professional Home Health Care v. Commonwealth of Kentucky Cabinet for Health and Family Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/professional-home-health-care-v-commonwealth-of-kentucky-cabinet-for-kyctapp-2023.