The Matter of Aaron Manor Rehabilitation and Nursing Center v. Howard A. Zucker

CourtNew York Court of Appeals
DecidedApril 23, 2024
Docket31
StatusPublished

This text of The Matter of Aaron Manor Rehabilitation and Nursing Center v. Howard A. Zucker (The Matter of Aaron Manor Rehabilitation and Nursing Center v. Howard A. Zucker) is published on Counsel Stack Legal Research, covering New York Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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The Matter of Aaron Manor Rehabilitation and Nursing Center v. Howard A. Zucker, (N.Y. 2024).

Opinion

State of New York OPINION Court of Appeals This opinion is uncorrected and subject to revision before publication in the New York Reports.

No. 31 In the Matter of Aaron Manor Rehabilitation and Nursing Center, LLC, et al., Respondents-Appellants, v. Howard A. Zucker, &c., et al., Appellants-Respondents.

Kate H. Nepveu, for appellants-respondents. F. Paul Greene, for respondents-appellants. New York State Health Facilities Association, Inc., amicus curiae.

RIVERA, J.:

On these cross appeals, we reject petitioners’ challenges to adjusted Medicaid

reimbursement rates issued to comply with amended Public Health Law (“PHL”) § 2808

(20) (d), which mandates the elimination of one component from the computation formula

used to set rates of for-profit residential health care facilities, on or after April 1, 2020. The

amendment and the adjusted rates do not result in a retroactive effect and petitioners failed

to establish that the rates are not “reasonable and adequate to meet costs” under PHL §

2807 (3) or that the rates violate their equal protection rights. We hold that respondents -1- -2- No. 31

may implement the recalculated rates for services provided as of April 2, 2020, and that

petitioners’ other claims were properly dismissed.

I.

Medicaid is “a joint federal-state program established pursuant to [T]itle XIX of the

Social Security Act (42 USC § 1396 et seq.), [which] pays for medical care for those

otherwise unable to afford it, including nursing home care for older people with low

incomes and limited assets” (Matter of Nazareth Home of the Franciscan Sisters v Novello,

7 NY3d 538, 542 [2006]). These services are delivered through a system of both

proprietary—or for-profit—and not-for-profit facilities (10 NYCRR § 86-2.10; § 86-2.19;

§ 86-2.20; § 86-2.21; § 86-2.22; 10 NYCRR 86-2.19 [a], [b], [c]). The New York State

Department of Health and its Commissioner administer New York’s Medicaid program,

including setting reimbursement rates to nursing home providers (see Social Services Law

§ 363-a [1], [2]). Unless “otherwise authorized by law,” or expressly exempted under PHL

§ 2808 (11), the Department must set reimbursement rates in advance of the dates of service

and notify facilities “at least sixty days prior to the beginning of an established rate period

for which the rate is to become effective,” as required by PHL § 2807 (7).

Medicaid reimbursement rates for facilities are made up of two components:

operating expenses and capital expenses, the latter of which includes interest for debt on

capital expenses and the cost of real property and equipment. The Department calculates

rates based on a complex multifactor formula that accounts for capital and noncapital

expenses. After the expiration of a 40-year period, the Commissioner had discretion to

-2- -3- No. 31

approve a payment factor not to exceed half of the capital cost reimbursement received by

the facility in the final year of its useful facility life (10 NYCRR 86-2.21 [e] [7]). Prior to

the legislative action underlying this appeal, a “residual equity reimbursement factor” was

part of the capital cost component of Medicaid rates of for-profit residential health care

facilities. This factor was a return on the facility’s “equity”, as defined in the regulations,

and was included in the facility’s annual capital costs during its useful facility life, which

is defined by regulation as the 40-year period after commencement of a nursing home’s

operations, with the opportunity for extension in certain circumstances that are not at issue

here (see 10 NYCRR § 86-2.10; § 86-2.19; §§ 86-2.20-86-2.22). In contrast, the capital

costs for not-for-profit facilities were and continue to be reimbursed based on depreciation,

which the Attorney General describes as “reimbursement [ ] divided over the estimated

useful life of a given item” (see Not-For-Profit Corporation Law 102 [a] [5]; 515 [a]; 10

NYCRR 86-2.19 [a], [b], [c]).

On April 3, 2020, in the wake of skyrocketing Medicaid costs in New York that

contributed to a $6 billion budget gap, the legislature passed the 2020-2021 Budget Law

which included Medicaid cost reduction measures (Jesse McKinley, The Governor and the

$6 Billion Budget Gap, NY Times [March 10, 2020],

https://www.nytimes.com/2020/03/10/nyregion/budget-medicaid-cuomo-ny.html [last

accessed Mar. 22, 2024]; Luis Ferré-Sadurní & Jesse McKinley, NY Hospitals Face $400

Million in Cuts Even as Virus Battle Rages, NY Times [Mar 30, 2020],

https://www.nytimes.com/2020/03/30/nyregion/coronavirus-hospitals-medicaid-

-3- -4- No. 31

budget.html [last accessed Mar. 22, 2024]). On the recommendation of the Medicaid

Redesign Team II, the legislature reduced the capital cost component 5% for all nursing

homes and amended PHL § 2808 (20) (d) to eliminate the residual equity reimbursement

factor (“the elimination clause”).1 The legislature mandated that both measures “shall take

effect immediately and shall be deemed to have been in full force and effect on and after

April 1, 2020” (Ch. 56, § 1, Part NN, § 3, 2020 N.Y. Laws [LRS], p. 274). The legislature

further specified that the elimination clause applies to rate periods as of this same date,

“[n]otwithstanding any contrary provision of law, rule or regulation” (PHL § 2808 [20]

[d]).

The Department determined that section 2808 (20) (d), as amended, required

adjustment of Medicaid rates and accordingly filed a State Plan Amendment that removed

residual equity payments on or after April 2, 2020. Upon approval by the federal Centers

for Medicare and Medicaid Services, the new rates were uploaded to the State payment

system. On August 7, 2020, by letter issued to for-profit facilities, the Department

announced the new rates, effective as of April 2, 2020.

1 The Medicaid Redesign Team II was tasked with developing recommendations to reduce Medicaid costs and “restore financial stability” to the Medicaid program by achieving $2.5 billion in savings. The team proposed a series of legislative changes for the 2020 budget, including the 5% reduction and elimination of residual equity reimbursement, that would reduce Medicaid expenditures (MRT II Executive Summary of Proposals, https://www.health.ny.gov/health_care/medicaid/redesign/mrt2/docs/2020-03- 19_executive_summary_of_proposals.pdf [Mar. 19, 2020]). -4- -5- No. 31

Petitioners, 116 for-profit nursing homes, filed this hybrid declaratory judgment and

article 78 proceeding against State respondents—the Department and its Commissioner

and the Director of the Budget—challenging the Department’s implementation of the

recalculated rates without the residual equity reimbursement factor. Simultaneously,

petitioners moved for a preliminary injunction to prevent respondents from enforcing the

equity elimination clause. Supreme Court granted petitioners’ motion for a preliminary

injunction against enforcement of the clause pending a final determination of the

proceeding. Petitioners thereafter filed an amended complaint which, among other things

sought an order barring enforcement of the elimination clause and a declaration that

implementation of the clause violates: (1) PHL § 2807 (7)’s prohibition on retroactive rate-

making and 60-day advance notice requirement; (2) PHL § 2807 (3)’s requirement that

reimbursement rates be “reasonable and adequate to meet the costs which must be incurred

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