Senno v. The Illinois Department of Healthcare and Family Services

2015 IL App (1st) 132837, 44 N.E.3d 1123
CourtAppellate Court of Illinois
DecidedOctober 20, 2015
Docket1-13-2837
StatusUnpublished

This text of 2015 IL App (1st) 132837 (Senno v. The Illinois Department of Healthcare and Family Services) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Senno v. The Illinois Department of Healthcare and Family Services, 2015 IL App (1st) 132837, 44 N.E.3d 1123 (Ill. Ct. App. 2015).

Opinion

2015 IL App (1st) 132837

SECOND DIVISION October 20, 2015

No. 1-13-2837

AREF SENNO, M.D., ) Appeal from the ) Circuit Court of Plaintiff-Appellant, ) Cook County ) v. ) ) No. 11 CH 23545 THE ILLINOIS DEPARTMENT OF HEALTHCARE ) AND FAMILY SERVICES, and JULIE HAMOS, ) ) Honorable ) David B. Atkins, ) Judge Presiding. ) Defendants-Appellees. )

PRESIDING JUSTICE PIERCE delivered the judgment of the court, with opinion. Justices Simon and Hyman concurred in the judgment and opinion.

OPINION

¶1 Plaintiff Aref Senno, M.D., appeals from a decision of the Illinois Department of

Healthcare and Family Services (Department) terminating his participation in a medical

assistance program administered by the Illinois’ Medical Assistance Program (Program) where

participating physicians receive reimbursement for treating Medicaid recipients. On appeal, Dr.

Senno argues: (1) the Administrative Law Judge (ALJ) improperly relied on Dr. Fatoki's

testimony; (2) the ALJ's findings were against the manifest weight of the evidence; and (3) the

ALJ failed to apply the correct standard in determining whether Dr. Senno had provided grossly 1-13-2837

inferior care. For the following reasons, we affirm the decision of the Department.

¶2 I. BACKGROUND

¶3 The Department requires physicians who participate in the medical assistance program to

maintain sufficient records “to fully and accurately document the nature, scope, details, and

receipt of the health care provided.” 305 ILCS 5/5-5 (West 2000). The Department may review

the participating physician’s medical records in order to monitor the quality of care given to

Medicaid recipients. Id.

¶4 In 2000, Dr. Senno, a physician with forty-plus years of experience and a long-time

provider in the Program, was asked by the Department to produce medical charts for 15

Medicaid patients. Although Dr. Senno treated many of these patients for a long period of time,

the Department specifically requested records spanning the period of April 1, 1998 to June 30,

1999. The Department’s Medical Quality Review Committee (Committee), which included the

Department’s primary consultant Dr. Adeyemi Fatoki, and two other physicians, reviewed the

medical records and met with Dr. Senno in September 2002 to discuss his medical practices. On

April 13, 2004, based on the Committee's findings, the Department notified Dr. Senno of its

intent to terminate him from the Program for violating the Illinois Public Aid Code (Code) (305

ILCS 5/1 et seq. (West 2002)), and the Illinois Administrative Code (89 Ill. Adm. Code §

140.16(a)(7), amended 28 Ill. Red. 4958 (eff. Mar. 3, 2004)) which states a vendor may be

terminated from participating in the Program for furnishing services that are (1) in excess of the

patient’s needs, (2) harmful to the patient, or (3) of grossly inferior quality; all such

determinations shall be based on competent medical judgment and evaluation.

¶5 The Department charged Dr. Senno with seven counts of providing care that was of

2 1-13-2837

grossly inferior quality, in excess of needs, and placed patients at risk of harm. The seven counts

included Dr. Senno’s alleged failure to: (count I) adequately treat a patient with congestive heart

failure; (count II) adequately manage a patient with diabetes mellitus; (count III) prescribe

antibiotics without any clinical indication; (count IV) properly evaluate a patient with urethral

discharge; (count V) properly prescribe medications; (count VI) address abnormal lab results

and; (count VII) evaluate a patient with a possible ulcer while the patient was taking nonsteroidal

drugs. Dr. Senno requested a hearing to review the Department’s decision. A hearing before an

ALJ commenced in May 2004 with two witnesses: Dr. Fatoki, a member of the reviewing

Committee, who testified as an expert for the Department without objection, and Dr. Senno, who

testified on his own behalf. This appeal concerns only count III, which alleged Dr. Senno

prescribed antibiotics to multiple patients on numerous occasions without clinical indication, and

count IV, which alleged Dr. Senno did not properly evaluate a patient for a sexually transmitted

disease. This court will discuss only those facts relevant to this appeal.

¶6 A. Count III

¶7 Count III alleged that Dr. Senno prescribed antibiotics without clinical indication where

antibiotics should only be used after a complete physical examination with laboratory results,

where appropriate, that document that a bacterial infection process is present in a patient that can

only be addressed by an antibiotic.

¶8 As an expert witness for the Department, Dr. Fatoki testified the proper standard of care

for prescribing antibiotics includes documenting enough information to justify a presumptive or

definitive diagnosis of a bacterial infection, or documenting enough circumstances to call for the

drug’s prophylactic use against the development of a bacterial infection or other serious

3 1-13-2837

condition. He explained a presumptive diagnosis is based on the patient’s medical history,

patient complaints, and on the physician’s objective findings from a physical exam and a

definitive diagnosis is based on diagnostic test results. Dr. Fatoki explained the standard of care

for prescribing antibiotics includes documentation in the medical record of the patient’s medical

history, complaints, physical exam findings, any test results, the diagnosis, and the treatment

plan. Dr. Fatoki testified the physician must document enough information in the medical record

to justify diagnosing the patient with a bacterial infection or using an antibiotic for a prophylactic

purpose.

¶9 Dr. Fatoki reviewed the medical records at issue and evaluated them against Dr. Senno’s

medical experience and background. The medical records of eight patients, representing 18 visits

to Dr. Senno, were introduced into evidence. Dr. Fatoki explained these medical records showed

Dr. Senno documented the patient’s complaints, his physical exam findings, and an antibiotic

prescription on most visits. Dr. Fatoki testified there was no medical history or diagnosis

documented in any of these records for any of the patients. Dr. Fatoki opined that Dr. Senno’s

documentation of symptoms and physical exam findings in the patients’ medical records could

indicate either a bacterial or a viral infection and were not enough to justify an antibiotic

prescription. Attached to the medical records were the billing statements for the visits. Dr. Fatoki

testified Dr. Senno documented the diagnosis of 12 of these visits in his billing statements as

“coughing,” “congestion,” or “sore throat,” which Dr. Fatoki explained are symptoms and not

bacterial infections warranting antibiotics. Other patient billing statements for the remaining

doctor’s visits contained the diagnosis of “cholelithiasis (gall bladder stones),” “renal stones,”

“cystitis (bacterial bladder inflammation),” “otitis media (ear infection)”and “renal infection,”

4 1-13-2837

yet Dr. Fatoki testified Dr. Senno’s medical records showed no clinical indication for these

diagnoses and no justification for the antibiotic treatment Dr. Senno prescribed.

¶ 10 Dr. Fatoki opined that Dr. Senno overall relied on too little information to diagnose these

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2015 IL App (1st) 132837, 44 N.E.3d 1123, Counsel Stack Legal Research, https://law.counselstack.com/opinion/senno-v-the-illinois-department-of-healthcare-and-family-services-illappct-2015.