Saint Alphonsus Regional Medical Center v. Elmore County

350 P.3d 1025, 158 Idaho 648, 2015 Ida. LEXIS 136
CourtIdaho Supreme Court
DecidedMay 22, 2015
Docket42175
StatusPublished
Cited by16 cases

This text of 350 P.3d 1025 (Saint Alphonsus Regional Medical Center v. Elmore County) 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
Saint Alphonsus Regional Medical Center v. Elmore County, 350 P.3d 1025, 158 Idaho 648, 2015 Ida. LEXIS 136 (Idaho 2015).

Opinion

W. JONES, Justice.

I. Nature of the Case

This appeal from the district court presents an issue of statutory interpretation of the Medical Indigency Act. Appellant Saint Alphonsus Regional Medical Center (Saint Alphonsus) submitted third party medical indigency applications on behalf of two patients. Respondent Elmore County and the Board of Elmore County Commissioners (the Board) denied the applications because the Board determined that the applications were incomplete. Saint Alphonsus filed petitions for judicial review. The district court consolidated the cases and affirmed the Board’s decision. Saint Alphonsus appeals to this Court. We vacate and remand for further proceedings.

II. Factual and Procedural Background

On January 9, 2013, Saint Alphonsus submitted a Combined Application for State and County Medical Assistance on behalf of a patient T.O. Similarly, on March 18, 2013, Saint Alphonsus submitted a Combined Application for State and County Medical Assistance on behalf on a patient T.A. T.O.’s and T.A.’s applications will be referred to collectively as the “Applications.”

Pages 1, 9, and 10 of the Applications had a line for the signature of the applicant. On Page 1, the applicant signs to acknowledge “that by completing this application form, it will be used to determine my eligibility” and “that I have read, understand, and will comply with the rules promulgated ... pursuant to Title 31, Chapter 35, Idaho Code.” On Page 9, the applicant signs a document titled “Patient Rights and Responsibilities for State and County Assistance,” and, on Page 10, the applicant signs a document titled “Release of Information.” Neither T.O. nor T.A. signed Pages 1, 9, and 10 of their Applications.

Page 9 also had a line for a signature “if by a third party applicant on behalf of the applicant,” which was signed by a representative of Saint Alphonsus. In addition, the Applications included a fax cover sheet, titled “Request for Medicaid Eligibility Determination: Medically Indigent Program.” This cover sheet also was signed by the Saint Alphonsus representative.

The Board initially denied both Applications. Saint Alphonsus appealed, and the Board upheld its initial denials of the Applications. In both cases, the Board recognized that one requisite finding “for the payment of indigent medical expenses” was “[a] ‘completed application’ must be timely filed.” The Board found that the Applications lacked T.O.’s and T.A.’s signatures on Pages 1, 9, and 10. In addition, the Board found that *650 the Applications did not contain all of T.O.’s and T.A.’s contact .and financial information. Based on these findings, the Board concluded that the Applications were not “completed application^]” as required by the Medical Indigency Act. Due to incompleteness, the Board did not determine eligibility — meaning that the Board did not determine whether (1) T.O. or T.A. were Idaho residents; (2) Elmore County was obligated to pay; (3) the medical services were necessary or emergent; or (4) T.O. or T.A. were medically indigent.

On August 1, 2013, Saint Alphonsus filed petitions for judicial review in both cases. The district court consolidated the cases.

On April 11, 2014, the district court issued a Memorandum Decision and Order. Contrary to the Board’s decision, the district court determined that responses on the Applications such as “N/A,” “No,” or “unknown” for T.O.’s and T.A.’s contact and financial information were complete responses. The district court determined that the Applications were incomplete, however, because neither Saint Alphonsus nor T.O. or T.A. provided a signature to swear to the truth of the matters asserted in the Applications. Due to the missing signatures, the district court concluded that the Applications were not “completed applications” as required by the Medical Indigency Act. Therefore, the district court affirmed the Board’s decision. 1 On April 11, 2014, the district court issued a final judgment.

Saint Alphonsus appeals to this Court. Kootenai Health and the Idaho Association of Counties, Inc. filed amicus curiae briefs.

III. Issue on Appeal

1. Whether the district court erred by affirming the Board’s decision that the Applications were not “completed” as required by the Medical Indigency Act.

IV. Standard of Review

“On an appeal from the district court, we review the decision of the district court to determine whether it correctly decided the issues presented to it.” Clear Springs Foods, Inc. v. Spackman, 150 Idaho 790, 797, 252 P.3d 71, 78 (2011).

“A county’s denial of an application for indigency benefits is reviewed under the Administrative Procedure Act, chapter 52, title 67, Idaho Code.” Sacred Heart Med. Ctr. v. Nez Perce Cnty. Comm’rs, 138 Idaho 215, 216, 61 P.3d 572, 573 (2002). “Judicial review of an administrative order is limited to the record.” Shobe v. Ada Cnty., Bd. of Comm’rs, 130 Idaho 580, 583, 944 P.2d 715, 718 (1997). The reviewing court shall affirm the agency action unless the agency’s findings, inferences, conclusions, or decisions are:

(a) in violation of constitutional or statutory provisions; (b) in excess of the statutory authority of the agency; (c) made upon unlawful procedure; (d) not supported by substantial evidence on - the record as a whole; or (e) arbitrary, capricious, or an abuse of discretion.

I.C. § 67-5279(3); see E. Idaho Reg’l Med. Ctr. v. Ada Cnty. Bd. of Cnty. Comm’rs, 139 Idaho 882, 883-84, 88 P.3d 701, 702-03 (2004). “A reviewing court may not substitute its judgment for that of the administrative agency on questions of fact, and will uphold an agency’s finding of fact if supported by substantial and competent evidence.” In re Ackerman, 127 Idaho 495, 496-97, 903 P.2d 84, 85-86 (1995). This Court exercises free review of interpretation of a statute. St. Luke’s Reg’l Med. Ctr., Ltd. v. Bd. of Comm’rs of Ada Cnty., 146 Idaho 753, 755, 203 P.3d 683, 685 (2009). “If the agency action is not affirmed, it shall be set aside, in whole or in part, and remanded for further proceedings as necessary.” I.C. § 67-5279(3).

*651 V. Analysis

Idaho’s Medical Indigency Act (hereinafter “the Act”), codified at Title 31, Chapter 35 of the Idaho Code, “requires counties to contribute to the cost of providing necessary medical care to county residents who are indigent.” St. Luke’s Magic Valley Reg’l Med. Ctr., Ltd. v.

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Bluebook (online)
350 P.3d 1025, 158 Idaho 648, 2015 Ida. LEXIS 136, Counsel Stack Legal Research, https://law.counselstack.com/opinion/saint-alphonsus-regional-medical-center-v-elmore-county-idaho-2015.