California Ass'n of Rural Health Clinics v. Douglas, No. 10-17574 (9th Cir. 2013)
Annotate this CaseThe Clinics filed suit challenging California Welfare and Institutions Code 14131.10, which eliminated certain Medi-Cal benefits that the state deemed optional, including adult dental, podiatry, optometry, and chiropractic services. The court reversed the district court's holding that the Clinics have a private right of action to challenge the Department's implementation of the state plan amendments (SPA) prior to obtaining approval; affirmed that the Clinics have a private right of action to bring a claim pursuant to 42 U.S.C. 1983 challenging the validity of section 14131.10; and reversed the district court's interpretation of the Medicaid Act, 42 U.S.C. 1396 et seq., holding that section 14131.10 impermissibly eliminated mandatory services from coverage.
Court Description: Medicaid Act. Reversing the district court’s summary judgment, the panel held that California legislation that eliminated coverage for certain healthcare services, including adult dental, podiatry, optometry, and chiropractic services, conflicted with the Medicaid Act and was therefore invalid. The panel reversed the district court’s holding that the California Association of Rural Health Clinics and a federally qualified health center had a private right of action to challenge the California Department of Health Services’ implementation of state Medicaid plan amendments prior to obtaining approval from the Centers for Medicare and Medicaid Services. The panel affirmed the district court’s holding that these health care providers had a private right of action to bring a claim pursuant to 42 U.S.C. § 1983 challenging the validity of California Welfare and Institutions Code § 14131.10. Following other circuits, the panel held that a private right of action exists to enforce rights created by 42 U.S.C. § 1396a(bb). The panel reversed the district court’s interpretation of the Medicaid Act and held that § 14131.10 impermissibly eliminated mandatory services from coverage. The panel held that it did not owe Chevron deference to the approval granted by the Centers for Medicare and Medicaid Services after the district court entered judgment. The panel concluded that the California Department of Health Services’ cross-appeal from the grant of injunctive and declaratory relief was moot.
The court issued a subsequent related opinion or order on September 17, 2013.
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