Sacred Heart Medical Center v. Kootenai County Commissioners

41 P.3d 215, 136 Idaho 787, 2001 Ida. LEXIS 144
CourtIdaho Supreme Court
DecidedNovember 28, 2001
Docket26864
StatusPublished
Cited by4 cases

This text of 41 P.3d 215 (Sacred Heart Medical Center v. Kootenai County Commissioners) is published on Counsel Stack Legal Research, covering Idaho Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sacred Heart Medical Center v. Kootenai County Commissioners, 41 P.3d 215, 136 Idaho 787, 2001 Ida. LEXIS 144 (Idaho 2001).

Opinion

WALTERS, Justice.

This is a medical indigency ease. The issue presented for review is whether all of *789 the outstanding bills of the applicant for county assistance, even those he has not been paying on, must be included in determining the applicant’s available resources. The Board of Commissioners for Kootenai County excluded an unrelated debt owing to the same hospital which had provided the medical services and a loan from friends that the applicant had not been making payments on and determined that there was discretionary income available after the applicant’s ordinary expenses, and concluded that the applicant was not medically indigent. On a petition by the hospital for judicial review, the district court upheld the Board’s determination. We also affirm the Board’s decision.

FACTS AND PROCEDURES

Monte S., a resident of Kootenai County, applied for medical indigency benefits after he was admitted to Sacred Heart Medical Center (SHMC) in Spokane for treatment of suspected heart disease in June of 1999. The total medical bills incurred for his treatment was $13,737.85, of which $12,039.85 was owed to SHMC. Kootenai County denied the application, finding that the applicant had discretionary income sufficient to pay the subject medical bills within three years in accordance with I.C. § 31-3502.

At the hearing on the appeal from the County’s denial of the indigency application, Kootenai County Assistance Officer, Marla Lewis, reported that the applicant had an income of $1,963.16 per month from Washington State Labor & Industries and monthly expenses totaling $1,424, leaving an excess of income over ordinary expenses of $538.73 per month. Lewis also calculated that the total medical bills from the June 1999 hospitalization, $13,737.85, could be paid by the applicant at the rate of $381 per month for 36 months, which would still leave the applicant with $157 per month for other expenses.

Monte S. testified to his monthly expenses, which included rent, electricity, sewer and garbage services, water and propane, food, sundries, automobile insurance, an automobile loan payment, and laundry. He also testified that he was spending $300 per month on counseling, which was to terminate in a couple of months and that the costs of his prescriptions for medicine, which he did not fill because he was unable to afford them, totaled $300 per month. With regard to other outstanding obligations, Monte S. testified that he had a loan from friends that he tried to pay when he could, but the amount of the loan was not disclosed. He owed another large obligation to SHMC for unrelated services provided in June of 1990, September of 1997, and April, June and December of 1998, with a balance due the hospital of $19,476.34. Monte S. testified that he had not made any payments on those hospital bills.

Subsequent to the hearing, the Commissioners learned that the applicant’s future medical bills for prescription drugs would be paid by the Veterans Administration. On February 4, 2000, the Commissioners entered findings of fact and conclusions of law. The Commissioners found the applicant’s present income to be $1,963.16 and his monthly expenses to be $1,324.43, leaving him $638.73 available per month to apply toward the medical provider bills for which he had made application for assistance. The Commissioners concluded that Monte S. was not “medically indigent” as defined by I.C. § 31-3502(1), in that he had sufficient resources with which to pay the debt within a three-year period, pursuant to the definition of available resources set forth in I.C. § 31-3502(17). The Commissioners denied the application for assistance.

SHMC timely filed a petition for judicial review of the Commissioners’ denial of the application. Because the facts of the case as found by the Commissioners were undisputed and supported by the record, the district court was presented only with a question of law. That question is whether all of the debts of an applicant must be considered by the Commissioners as a present expense regardless of whether the applicant actually is paying on that indebtedness.

The district court determined, consistent with the Commissioners’ findings, that Monte S. “is capable of paying off the claimed medical expenses within a three-year period and making a regular payment in some amount toward his previously incurred medical ex *790 penses.” The district court relied on Application of Ackerman, 127 Idaho 495, 903 P.2d 84 (1995), for the proposition that counties are not required to subtract payments on all outstanding obligations such as credit card debt and other discretionary expenses. The district court distinguished this case from Ackerman in that the medical care that Monte S. had previously received was necessary and not the byproduct of a lifestyle choice, but the court nevertheless held that the prior medical care debt was an unsecured debt to be treated in the same manner as any other obligation.

The district court acknowledged that simply because an applicant was delinquent in making payments on an outstanding debt was not necessarily a sufficient reason to exclude such debts from the determination of a claimant’s monthly expenses. Nevertheless, the district court affirmed the decision of the Commissioners, concluding that the Commissioners properly determined that the prior medical expenses and the unpaid loan to friends were obligations which were not required to be included in the calculation of the claimant’s available resources.

SHMC has appealed from the district court’s opinion on review of the Commissioners’ action.

ISSUES ON APPEAL

1. Did the Commissioners err in refusing to consider unpaid prior medical bills when determining whether the applicant had sufficient discretionary income to pay the medical bill for which the applicant sought medical indigency benefits?

2. Should SHMC receive an award of attorney fees at the district court level and on appeal?

STANDARD OF REVIEW

The denial of an application for indigency benefits is reviewed under the Administrative Procedure Act, Idaho Code tit. 67, ch. 52. I.C. § 31-3505; Bonner General Hospital v. Bonner County, 133 Idaho 7, 981 P.2d 242 (1999). A reviewing court may not substitute its judgment for that of the administrative agency on questions of fact. Application of Ackerman, 127 Idaho 495, 903 P.2d 84 (1995). Only if substantial rights of the appellant have been prejudiced may a reviewing court reverse the agency’s decision or remand for further proceedings. Id.; I.C. § 67-5279(4). The substantial evidence rule requires the reviewing court to determine whether the agency’s findings of fact are “reasonable.” Intermountain Health Care v. Board of County Comm’rs, 107 Idaho 248, 253, 688 P.2d 260, 265 (1984).

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Bluebook (online)
41 P.3d 215, 136 Idaho 787, 2001 Ida. LEXIS 144, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sacred-heart-medical-center-v-kootenai-county-commissioners-idaho-2001.