The Mississippi Methodist Hospital and Rehabilitation Center, Inc. d/b/a Methodist Specialty Care Center v. Mississippi Division of Medicaid and Drew L. Snyder, in his Official Capacity as Executive Director of the Mississippi Division of Medicaid

CourtMississippi Supreme Court
DecidedJune 10, 2021
Docket2019-SA-01558-SCT
StatusPublished

This text of The Mississippi Methodist Hospital and Rehabilitation Center, Inc. d/b/a Methodist Specialty Care Center v. Mississippi Division of Medicaid and Drew L. Snyder, in his Official Capacity as Executive Director of the Mississippi Division of Medicaid (The Mississippi Methodist Hospital and Rehabilitation Center, Inc. d/b/a Methodist Specialty Care Center v. Mississippi Division of Medicaid and Drew L. Snyder, in his Official Capacity as Executive Director of the Mississippi Division of Medicaid) is published on Counsel Stack Legal Research, covering Mississippi Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Mississippi Methodist Hospital and Rehabilitation Center, Inc. d/b/a Methodist Specialty Care Center v. Mississippi Division of Medicaid and Drew L. Snyder, in his Official Capacity as Executive Director of the Mississippi Division of Medicaid, (Mich. 2021).

Opinion

IN THE SUPREME COURT OF MISSISSIPPI

NO. 2019-SA-01558-SCT

THE MISSISSIPPI METHODIST HOSPITAL AND REHABILITATION CENTER, INC. d/b/a METHODIST SPECIALTY CARE CENTER

v.

MISSISSIPPI DIVISION OF MEDICAID AND DREW L. SNYDER, IN HIS OFFICIAL CAPACITY AS EXECUTIVE DIRECTOR OF THE MISSISSIPPI DIVISION OF MEDICAID

DATE OF JUDGMENT: 09/12/2019 TRIAL JUDGE: HON. J. DEWAYNE THOMAS TRIAL COURT ATTORNEYS: DION JEFFERY SHANLEY ANDY LOWRY BEATRYCE McCROSKY TOLSDORF THOMAS L. KIRKLAND, JR. SAMUEL PHILIP GOFF JANET McMURTRAY COURT FROM WHICH APPEALED: HINDS COUNTY CHANCERY COURT ATTORNEY FOR APPELLANT: THOMAS L. KIRKLAND, JR. ATTORNEYS FOR APPELLEES: JANET McMURTRAY OFFICE OF THE ATTORNEY GENERAL BY: LAURA L. GIBBES SAMUEL PHILIP GOFF NATURE OF THE CASE: CIVIL - STATE BOARDS AND AGENCIES DISPOSITION: AFFIRMED - 06/10/2021 MOTION FOR REHEARING FILED: MANDATE ISSUED:

BEFORE KING, P.J., CHAMBERLIN AND ISHEE, JJ.

KING, PRESIDING JUSTICE, FOR THE COURT:

¶1. Methodist Specialty Care Center (Specialty), a hospital-based nursing facility owned by Methodist Rehabilitation Center (Methodist), included an allocation of Methodist’s

Medicaid Assessment in its nursing-facility cost report. The Division of Medicaid (DOM)

disallowed the allocation for Specialty’s cost report, finding that Methodist’s assessment was

not an allowable cost for Specialty. Specialty appealed the decision to the Hinds County

Chancery Court, which affirmed the decision of the DOM. Because Methodist’s assessment

was not an allowable cost for Specialty under the plain language of the State Medical Plan

(Plan) and the Medicaid statutory structure, this Court affirms the decisions of the DOM and

the chancery court.

FACTS AND PROCEDURAL HISTORY

¶2. Specialty is a nursing facility owned by Methodist, a hospital. Hospitals and nursing

facilities are treated as completely separate providers under the Mississippi Medicaid

program and file separate cost reports. This is true even when the nursing facility is hospital

based. Both Specialty and Methodist are participating providers in the Mississippi Medicaid

program.

1. Medicaid Treatment of Nursing Facilities and Hospitals as Separate Providers

¶3. The DOM levies assessments on various types of facilities, and these assessments help

fund the Medicaid program. Miss. Code Ann. § 43-13-145 (Rev. 2015). Nursing facilities

pay an assessment for each licensed and occupied bed, and that assessment is “equal to the

maximum rate allowed by federal law or regulation[.]” Miss. Code Ann. § 43-13-145(1)(a)

(Rev. 2015). Hospitals pay an assessment calculated by a variety of factors. Miss. Code

2 Ann. § 43-13-145(4) (Supp. 2020).1

¶4. The DOM reimburses qualified providers for covered services pursuant to the

applicable Plan. These reimbursements are determined based on the provider’s cost data,

submitted in compliance with Medicaid’s cost reporting rules. Hospitals submit costs and

are reimbursed in accordance with State Plan 4.19-A. Nursing facilities submit costs and are

reimbursed in accordance with State Plan 4.19-D. Thus, nursing facilities and hospitals have

separate assessments, separate reimbursements, and file separate cost reports.

2. Medicare and Business Principles Treatment of Methodist and Specialty as One Entity

¶5. It is undisputed that, for business purposes, Methodist and Specialty are one entity.

Methodist owns Specialty, and they do not have separate finances or operating organizations.

It is likewise undisputed that, for Medicare purposes, Methodist and Specialty are one entity.

Methodist is the Medicare “provider,” and Specialty is one of its “cost centers.” Ctrs. For

Medicare & Medicaid Servs., Provider Reimbursement Manual 15-1 § 2302.16,

https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Paper-Based

-Manuals-Items/CMS021929 (last visited May 27, 2021).2 3 Methodist may allocate costs to

1 Intermediate care facilities for the intellectually disabled and psychiatric residential treatment facilities are also separate Medicaid providers and are separately assessed. Miss. Code Ann. § 43-13-145(2), (3) (Rev. 2015). 2 This source is referred to as “CMS PRM 15-1” throughout this opinion. 3 The federal Centers for Medicare and Medicaid Services (CMS) issue a Provider Reimbursement Manual (PRM). CMS PRM 15-1 guidelines refer to the Medicare guidelines, which do not separate hospitals and hospital-based nursing facilities, but do provide guidelines for allowable costs. For Medicare purposes, Methodist is the “provider” and Speciality is treated as one of its cost centers, not as a separate provider.

3 its various “cost centers” for Medicare reporting purposes.

¶6. Medicare guidelines provide that two types of departments within a provider exist.

CMS PRM 15-1 § 2306. Revenue-producing cost centers generate patient-care revenue and

include nursing facilities such as Specialty. Id. Nonrevenue-producing cost centers do not

generate patient-care revenue but are used by other departments as a service. Id. Examples

of nonrevenue-producing cost centers include laundry, dietary, and housekeeping. Id. “[T]he

cost of the revenue-producing centers should include both its direct expenses and its

proportionate share of the costs of each nonrevenue-producing center (indirect costs) based

on the amount of services received.” Id. Methodist uses the “step-down method” to

determine these allocations. CMS PRM 15-1 § 2306.1. It consequently allocates a portion

of certain costs to Specialty.

3. Medicaid Treatment of Costs for Nursing Facilities Within Hospitals

¶7. Medicaid requires nursing facilities to use Medicaid forms and schedules for Medicaid

cost reporting. Medicaid Instructions for Filing Long-Term Care Facility Cost Report,

https://medicaid.ms.gov/wp-content/uploads/2020/06/Instructions-2020-revision

-doc-6.24.20-1.pdf (last visited May 27, 2021). Medicare “cost reporting forms are not

acceptable in lieu of these forms.” Id. However, Medicaid acknowledges that hospital-based

nursing facilities may use cost allocation to determine certain revenue and costs and provides

that “[h]ospital-based facilities . . . which use the Medicare forms for step-down in

completing their cost report must submit a copy of the applicable Medicare cost report

forms.” Id. This recognizes that when stand-alone nursing facilities directly incur some

4 certain costs, hospital-based nursing facilities may not directly incur those costs because the

hospital incurs them for the nursing facility and its many other departments.

4. Inclusion of a Portion of Methodist’s Assessment on Specialty’s Cost Report

¶8. Manuel Pilgrim testified that he began working as the Medicaid Director of Financial

and Compliance Review in 2015. In his audit review of 2012 cost reports, he noticed that

some nursing facilities had been including an allocation of the hospital assessment in their

cost reports. Medicaid identified this as incorrect and began adjusting nursing-home cost

reports accordingly. Pilgrim testified that hospital accounting and reimbursement methods

changed in 2012 in a manner such that, prior to 2012, it would not have mattered much where

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Secretary of Agriculture v. United States
347 U.S. 645 (Supreme Court, 1954)
Dixon v. United States
381 U.S. 68 (Supreme Court, 1965)
Miss. State Bd. of Nursing v. Wilson
624 So. 2d 485 (Mississippi Supreme Court, 1993)
Sierra Club v. MISS. ENVIRO. QUALITY
943 So. 2d 673 (Mississippi Supreme Court, 2006)
United States v. AMC Entertainment, Inc.
549 F.3d 760 (Ninth Circuit, 2008)
MS DEPT. OF HEALTH v. Natchez Community Hosp.
743 So. 2d 973 (Mississippi Supreme Court, 1999)
Beverly Enterprises v. Miss. Div. of Medicaid
808 So. 2d 939 (Mississippi Supreme Court, 2002)
Perez v. Mortgage Bankers Assn.
575 U.S. 92 (Supreme Court, 2015)
Crossgates River Oaks Hosp. v. Miss. Div. of Medicaid & David J. Dzielak
240 So. 3d 385 (Mississippi Supreme Court, 2018)
Cindy W. King v. Mississippi Military Department
245 So. 3d 404 (Mississippi Supreme Court, 2018)
Adams v. Mississippi State Oil & Gas Board
139 So. 3d 58 (Mississippi Supreme Court, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
The Mississippi Methodist Hospital and Rehabilitation Center, Inc. d/b/a Methodist Specialty Care Center v. Mississippi Division of Medicaid and Drew L. Snyder, in his Official Capacity as Executive Director of the Mississippi Division of Medicaid, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-mississippi-methodist-hospital-and-rehabilitation-center-inc-dba-miss-2021.