The State of Georgia v. Brooks-LaSure

CourtDistrict Court, S.D. Georgia
DecidedJuly 15, 2024
Docket2:24-cv-00016
StatusUnknown

This text of The State of Georgia v. Brooks-LaSure (The State of Georgia v. Brooks-LaSure) is published on Counsel Stack Legal Research, covering District Court, S.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The State of Georgia v. Brooks-LaSure, (S.D. Ga. 2024).

Opinion

In the United States District Court for the Southern District of Georgia Brunswick Division

THE STATE OF GEORGIA, and GEORGIA DEPARTMENT OF COMMUNITY HEALTH,

Plaintiffs, 2:24-CV-16 v.

CHIQUITA BROOKS-LASURE, in her official capacity as Administrator of the Centers for Medicare and Medicaid Services, et al.,

Defendants.

ORDER Before the Court is Plaintiffs State of Georgia and Georgia Department of Community Health’s (collectively, “Georgia”) motion for summary judgment, dkt. no. 19, as well as the federal government Defendants’ motion for summary judgment, dkt. no. 21. The motions have been thoroughly briefed and are ripe for review. Dkt. Nos. 19, 21, 22, 23, 25. The Court heard oral argument on June 21, 2024. Dkt. No. 27. For the reasons stated below, Plaintiffs’ motion is DENIED, and Defendants’ motion is GRANTED. BACKGROUND This case is about whether the Centers for Medicare and Medicaid Services (“CMS”) violated the Administrative Procedure Act (“APA”) when it denied Georgia’s request to prolong the implementation period for the Georgia Pathways to Coverage program. Because Georgia’s request did not comply with the rules

governing extensions of the program, the Court finds that CMS did not violate the APA. This case is the second round of litigation in federal court over the Georgia Pathways to Coverage Medicaid expansion program. For a full recitation of the facts of this case, refer to the Court’s previous order. Georgia v. Brooks-LaSure, No. 2:22-CV-6, 2022 WL 3581859 (S.D. Ga. Aug. 19, 2022). A condensed version of the first case is as follows: Georgia created the Pathways program as a Medicaid demonstration project that expands Medicaid coverage to Georgians who do not qualify for traditional Medicaid.1 Id. at *3. Coverage under Georgia Pathways is conditional, meaning that applicants must satisfy certain eligibility requirements. Id. The

rules governing the program are set forth in an agreement between Georgia and CMS (the “Agreement”). Dkt. No. 19-3. After the parties entered into the Agreement and CMS approved Georgia Pathways, CMS did an about-face and withdrew its approval. 2022 WL 3581859, at *6. Georgia sued. Id. Georgia won. Id. The Court found that CMS’s rescission violated the APA because “it was arbitrary and

1 A Medicaid demonstration project is a waiver from the requirements of the Social Security Act. See 42 U.S.C. § 1315. Demonstration projects are governed by 42 U.S.C. § 1315 and federal regulations promulgated by CMS, 42 C.F.R. § 400 et seq. capricious on numerous, independent grounds.” Id. at *23. As a result, the Court vacated CMS’s rescission of Georgia Pathways. Id.

Georgia renewed its effort to implement the Pathways program. Due to delays caused by the first round of litigation, however, Georgia had to reassemble major components of the program. Dkt. Nos. 19-15, 19-16. By November 2022, Georgia had completed this work and planned for the program to go into effect in the summer of 2023. Dkt. No. 19-16. On February 24, 2023, Georgia asked CMS to “amend the effective dates” of the program. Dkt. No. 19-23 at 2. More specifically, Georgia asked CMS to revise the program’s end date to September 30, 2028. Id. Pursuant to the Agreement, the implementation period for Georgia Pathways is October 15, 2020, to September 30, 2025. Dkt. No. 19-3 at 2. Georgia explained in its

2023 letter that extending the end date to 2028 would “provide the state with a full five-year period in which to operate, monitor, evaluate, and assess the effectiveness of the Pathways to Coverage 1115 Demonstration.” Id. at 2. Georgia further explained that “[b]ased on the limited time remaining in the Demonstration and [the] implementation date of July 1, 2023,” Georgia would “have limited time in which to evaluate and assess the effectiveness of the demonstration waiver prior to its expiration.” Id. Georgia told CMS that submitting a formal extension request would be premature because Georgia “would have just collected its baseline data and would not have had an opportunity to conduct any comparisons or perform its evaluation activities.” Id. at 6.

On October 5, 2023, CMS denied Georgia’s request to amend the end date to 2028. Dkt. No. 19-29. This was because CMS found that Georgia had failed to comply with the requirements necessary for CMS to grant an extension. Id. The Agreement contemplates two ways to change the Pathways program: amendments and extensions. Dkt. No. 19-3. “Changes related to eligibility, enrollment, benefits, beneficiary rights, delivery systems, cost sharing, sources of non-federal share of funding, budget neutrality, and other comparable program elements must be submitted to CMS as amendments to the demonstration.” Id. at 6. Amendment requests are subject to approval at the discretion of the Department of Health and Human Services Secretary. Id. On the other hand, extensions govern

changes to the temporal length of the program. Id. at 7. To obtain an extension, the state must “submit an application to CMS from the Governor or Chief Executive Officer of the state in accordance with the requirements of 42 Code of Federal Regulations (CFR) 431.412(c).” Id. 42 C.F.R. § 431.412(c) requires that states seeking to extend the duration of a demonstration project submit a formal extension request. Id. “A request to extend an existing demonstration . . . will be considered only if it is submitted at least 12 months . . . or 6 months prior to the expiration date of the demonstration.” Id. “An application to extend an existing demonstration will be considered complete” when a state provides the following:

(i) A historical narrative summary of the demonstration project, which includes the objectives set forth at the time the demonstration was approved, evidence of how these objectives have or have not been met, and the future goals of the program.

(ii) If changes are requested, a narrative of the changes being requested along with the objective of the change and the desired outcomes.

(iii) A list and programmatic description of the waivers and expenditure authorities that are being requested for the extension period, or a statement that the State is requesting the same waiver and expenditure authorities as those approved in the current demonstration.

(iv) Summaries of External Quality Review Organization (EQRO) reports, managed care organization (MCO) and State quality assurance monitoring, and any other documentation of the quality of and access to care provided under the demonstration, such as the CMS Form 416 EPSDT/CHIP report.

(v) Financial data demonstrating the State’s historical and projected expenditures for the requested period of the extension, as well as cumulatively over the lifetime of the demonstration. This includes a financial analysis of changes to the demonstration requested by the State.

(vi) An evaluation report of the demonstration, inclusive of evaluation activities and findings to date, plans for evaluation activities during the extension period, and if changes are requested, identification of research hypotheses related to the changes and an evaluation design for addressing the proposed revisions.

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