Tulare Local Healthcare District

CourtUnited States Bankruptcy Court, E.D. California
DecidedApril 27, 2021
Docket17-13797
StatusUnknown

This text of Tulare Local Healthcare District (Tulare Local Healthcare District) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tulare Local Healthcare District, (Cal. 2021).

Opinion

UNITED STATES BANKRUPTCY COURT 1 EASTERN DISTRICT OF CALIFORNIA 2 FRESNO DIVISION 3 4 In re ) Case No. 17-13797-B-9 ) 5 TULARE LOCAL HEALTHCARE ) DC No. GL-1 ) 6 DISTRICT, ) ) 7 Debtor. ) ) 8 ) ) 9 10

11 MEMORANDUM DECISION ON CREDITOR DEPARTMENT OF HEALTH CARE SERVICES’ MOTION FOR LEAVE TO FILE AMENDED CLAIM 197 12 13 Before: René Lastreto II, Bankruptcy Judge __________________ 14 15 Grant Lien, Deputy Attorney General of California, Sacramento, 16 CA, for the Department of Health Care Services, Creditor. 17 Riley C. Walter, WANGER JONES HELSLEY, PC, Fresno, CA, for Tulare Local Health Care District, dba Tulare Regional Medical 18 Center, Debtor. 19 _____________________ 20 21 RENÉ LASTRETO II, Bankruptcy Judge: 22 23 INTRODUCTION 24 To receive payments on allowed claims provided by a Chapter 25 9 Plan of Adjustment under the Bankruptcy Code, the creditor 26 must file a proof of claim on the approved form.1 Filed claims 27 can be amended. The question here is “when?” 28 1 Unless specified otherwise, all chapter, code and rule references are to the Bankruptcy Code, 11 U.S.C. §§ 101-1532, and the Federal Rules of 1 In the Ninth Circuit, amendments to claims are “liberally” 2 allowed unless leave to amend would prejudice an opposing party. 3 “Prejudice,” though, means more than having to litigate about or 4 pay the claim. 5 The California Department of Health Care Services (“DHCS”) 6 timely filed a proof of claim on the approved form in the Tulare 7 Local Health Care District’s (“District”) Chapter 9 case. But 8 the claim stated the amount was “[u]ndetermined at this time.” 9 After District objected to allowance of the claim, filed a 10 Disclosure Statement and Plan of Adjustment, obtained court 11 approval of the Disclosure Statement, served the Disclosure 12 Statement and Plan, District’s creditors voted to overwhelmingly 13 support the Plan, and the court confirmed the Plan, DHCS filed a 14 motion to amend the claim from “undetermined” to $5,520,423.33. 15 DHCS had many reasons for the delay in specifying the claim 16 amount. The court considered those and the prejudice District, 17 its creditors, and other constituencies would experience if 18 leave to amend was granted. Based on the evidence and status of 19 the Chapter 9 case, the court DENIES the motion for leave to 20 amend. 21 22 FACTS 23 Background 24 Since 2002, District was a participant in a program 25 administered by DHCS providing supplemental reimbursement to 26 qualified health providers for outpatient services rendered to 27 Medi-Cal patients. Doc. 2260. Annually, District provided cost 28 Bankruptcy Procedure, Rules 100 1-9037. The Federal Rules of Civil Procedure are referred to as “Civ. Rule.” 1 reports to DHCS for eligible outpatient services. Doc. 1513. 2 Under California’s reimbursement plan, DHCS should annually 3 reconcile District’s cost reports with settled/audited cost 4 reports. After reconciliation, any underpayment or overpayment 5 is to be reflected annually in DHCS’s supplemental payment to 6 the participating provider under the program. Doc. 2260. 7 Though District submitted its reports annually, no 8 reconciliation followed. Docs. 1513, 2397. That is until after 9 this case was filed, a claim deadline imposed, and District 10 objected to DHCS’s claim – over sixteen years after the 11 reimbursement program began. 12 Why? Because, DHCS says, as of April 2018 (when it filed 13 its proof of claim 197 in an “undetermined” amount) “final 14 reconciliations [were] still pending.”2 Also, DHCS says “the 15 reconciliation process is inherently complicated and necessarily 16 time consuming.” Doc. 2259. Time is consumed because interim 17 payments to District (and other providers) are calculated using 18 “cost-to-charge ratios” from provider cost reports and Medi-Cal 19 Fee-for-Service (“FFS”) charges. Id. But final reconciliations 20 require audited cost reports and FFS charges and payments 21 reconciled from the State’s “internal Medicaid Management 22 Information System (“MMIS”).” Id. 23 DHCS “experienced difficulties” during this sixteen-year 24 period due to: “difficulties in extracting [outpatient fee-for- 25 service] charges and revenues from MMIS;” “workforce 26 27 28 Mendiol2 aD e wc al s. “S Sh ei ce tl ia o nM e Cn hd ii eo fl a o, f a Mt et da ic -h C. a lt o S up pr po lo ef m eo nf t ac ll a Pi am y m1 e9 n7 t. S eT ch te in o, n ,M s S. t aff Services Manager II, for the Safety New Financing Division of . . . [DHCS].” 1 reductions;” and “inefficiencies with workflow logistics, some 2 of which lasted for years.” Id. 3 Once DHCS “developed the necessary framework for extracting 4 the data, additional nuances needed to be addressed.” DHCS had 5 to determine the amount of provider cost associated with 6 professional services by using all providers’ MMIS data so it 7 could be excluded. This proved to be “difficult” and led to 8 further delays. Id. 9 Meanwhile, beset with many financial and other problems 10 complicated by its former management arrangement, District filed 11 this Chapter 9 case September 30, 2017. Less than three months 12 later, DHCS was added to the creditor list. After entering an 13 order for relief, the court issued an order setting the claims 14 bar date for April 10, 2018. Doc. 377. 15 Thirteen months later, District filed its Plan of 16 Adjustment and Disclosure Statement. Docs. 1440, 1441. The 17 Disclosure Statement said allowed unsecured claims would be 18 between $16.5 million and $26 million held by about 250 19 claimants. Doc. 1441. In a footnote, District explained the 20 wide range of estimated claim amounts was due to disputed 21 government reimbursement claims. District said it “believed” 22 that after the audits are completed within two to three years, 23 the overpayment claims will be eliminated. “Other reductions 24 may be achieved through objections to claims and pending or to 25 be filed.” Id. 26 In August 2019, the Plan of Adjustment was confirmed.3 27 Doc. 1618. The success of District’s reorganization hinged on 28 3 DHCS was served all the ballot solicitation materials on July 9, 2019. Doc. 1545 at 11. DHCS did not return a ballot or participate in the 1 two major conditions. First, District needed to lease most of 2 its facilities. They did. Adventist Health is the lessee and 3 is operating the hospital and accompanied facilities. Second, 4 certain loans needed to be repaid which facilitated 5 restructuring of some of District’s bond debt. District managed 6 that as well. 7 Cash flow from the lease payments and other sources under 8 the plan permit District to attend to certain deferred 9 maintenance projects and other needs. Under the Plan, the 10 unsecured creditor class (class 8) is to receive between 19.2% 11 and 30.3% distributions on allowed claims over five years. But 12 payments do not begin until 2025. 13 14 Chapter 9 15 A word about Chapter 9. This chapter of the Bankruptcy 16 Code is available only to “municipalities” as defined in 11 17 U.S.C. § 101 (40). District is a municipality. This chapter 18 permits reorganization of municipalities and represents a 19 careful application of reorganization policies under bankruptcy 20 law. Care is necessary because of the constitutional limitation 21 on Federal “interference” with state governments. 22 Very similar to Chapter 11, Chapter 9 incorporates many 23 provisions of the Bankruptcy Code. A list of applicable 24 sections is found in 11 U.S.C. § 901 (a). Among those 25 incorporated are the provisions dealing with filing and 26 27 28 solicitation process. Docs. 159 3-97.

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