Saint Alphonsus Regional Medical Center v. Gooding County

356 P.3d 377, 159 Idaho 84, 2015 Ida. LEXIS 232
CourtIdaho Supreme Court
DecidedSeptember 4, 2015
Docket42243
StatusPublished
Cited by26 cases

This text of 356 P.3d 377 (Saint Alphonsus Regional Medical Center v. Gooding 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. Gooding County, 356 P.3d 377, 159 Idaho 84, 2015 Ida. LEXIS 232 (Idaho 2015).

Opinion

BURDICK, Justice.

Gooding County appeals the district court’s decision reversing the Gooding County Board of Commissioners’s (BOCC) decision affirming the denial of a third-party medical indigency application. On August 27, 2013, Saint Alphonsus Regional Medical Center (Hospital) submitted a third-party medical indigency application to the Department of Health and Welfare (Department) on behalf of a patient who had been hospitalized at its facility since July 27, 2013. The County Clerk denied the application on the basis that it was untimely filed, and the BOCC affirmed. The Hospital appealed that decision to the Gooding County district court, which reversed the decision and remanded for further proceedings. Gooding County then appealed to this Court. On appeal, Gooding County asserts that the district court erred when it held that the date of admission is excluded when calculating an application’s deadline under Idaho Code section 31-3505(3). We affirm.

I. FACTUAL AND PROCEDURAL BACKGROUND

On July 27, 2013, D.J.W. (Patient) was admitted to the Hospital and hospitalized due to injuries he sustained in a motor vehicle accident. On August 27, 2013, the Hospital filed a First Party Combined County Medical Assistance Application with the Department on Patient’s behalf. The County Service Director investigated the application and ultimately concluded that the application should be denied as untimely. On September 9, 2013, the County Clerk issued an initial determination denying the application on the basis that it was not timely filed.

The Hospital subsequently appealed the initial determination to the BOCC, arguing that the County Clerk incorrectly counted the date of admission as day one of the thirty-one day application deadline. Following a hearing, the BOCC issued its Findings of Fact Conclusion and Decision, which affirmed the denial of the application on the basis that it was untimely filed.

The Hospital then petitioned the Gooding County district court for review. The district court concluded that the BOCC erred when it included the date of admission in calculating the application deadline. Consequently, the district court reversed the BOCC’s decision and remanded to the BOCC to approve the application. Gooding County then moved the district court for reconsideration, which the district court denied. Gooding County timely appealed to this Court.

II. STANDARD OF REVIEW

The Idaho Administrative Procedure Act governs this Court’s review of a county board of commissioners’s denial of an application for indigency benefits. I.C. § 67-5201 et seq.; I.C. § 31-1506; St. Luke’s Magic Valley Reg'l Med. Ctr., Ltd. v. Bd. of Cnty. Comm’rs of Gooding Cnty., 150 Idaho 484, 486, 248 P.3d 735, 737 (2011). The decision may be overturned on judicial review only where it: (a) violates statutory or constitutional provisions; (b) exceeds statutory authority; (c) was made upon unlawful procedure; (d) is not supported by substantial evidence in the record as a whole; or (e) is arbitrary, capricious, or an abuse of discretion. I.C. § 67-5279(3). On an appeal from the decision of the district court on a petition for judicial review, we review the court’s decision to determine whether it correctly *86 decided the issues presented to it. Burns Holdings, LLC v. Teton Cnty. Bd. of Comm’rs, 152 Idaho 440, 443, 272 P.3d 412, 415 (2012).

III. ANALYSIS

The only issue on appeal is whether the Hospital timely filed the application for indigency benefits under Idaho Code section 31-3505(3). The parties do not dispute that Patient was admitted to the Hospital on July 27, 2013, and that Patient was subsequently hospitalized due to the injuries he sustained in a motor vehicle accident. There is also no dispute that the Hospital filed a First Party Combined Application for medical assistance with the Department, which the Department received on August 27, 2013. The parties disagree on whether the first day of admission to the hospital counts towards the thirty-one day filing deadline under Idaho Code section 31-3505(3). Gooding County argues that the statute’s plain language indicates that the day of admission must be included in determining the application deadline. The Hospital, on the other hand, asserts that Idaho Code section 73-109 directly controls the computation of time in this ease, and that the district court correctly concluded that the date of admission must be excluded when determining the application deadline.

The policy behind Chapter 35 is to encourage personal responsibility for medical care and to charge counties with the duty to care for individuals that cannot meet this responsibility. I.C. § 31-3501. “In construing [Idaho Code § 31-3501, et seq.], this Court has stated that the legislature’s general intent in enacting the medical indigency assistance statutes is twofold: to provide indigents with medical care and to allow hospitals to obtain compensation for services rendered to indigents.” Univ. of Utah Hosp. v. Ada Cnty. Bd. of Comm’rs, 143 Idaho 808, 810, 153 P.3d 1154, 1156 (2007) (citation omitted) (internal quotation marks omitted). Consequently, Idaho’s Medical Indigency Act requires counties to contribute to the cost of providing necessary medical care to county residents who are indigent. See I.C. § 31-3501. This Court has stated that placing too heavy a burden on providers to collect on services rendered to medical indigents could reduce hospitals’ ability to provide such services. Univ. of Utah Hosp., 143 Idaho at 811, 153 P.3d at 1157.

Idaho Code section 31-3505 governs the time and manner of filing applications for such financial assistance from the counties. That section was amended to its present form effective July 1, 2011. It provides, in relevant part:

31-3505. Time and manner of filing applications for financial assistance.
Applications for financial assistance shall be filed according to the following time limits. Filing is complete upon receipt by the clerk or the department.
(2) A completed application for emergency necessary medical services shall be filed with the clerk any time within thirty-one (31) days beginning with the first day of the provision of necessary medical services from the provider, except as provided in subsection (3) of this section.
(3) In the case of hospitalization, a completed application for emergency necessary medical services shall be filed with the department any time within thirty-one (31) days of the date of admission.

I.C. § 31-3505(2), (3). Because Patient was hospitalized, subsection (3) applies and we must determine when the clock starts running for purposes of determining the application deadline.

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Bluebook (online)
356 P.3d 377, 159 Idaho 84, 2015 Ida. LEXIS 232, Counsel Stack Legal Research, https://law.counselstack.com/opinion/saint-alphonsus-regional-medical-center-v-gooding-county-idaho-2015.