Gardena Hospital, L.P. v. Baass
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In this case, Gardena Hospital in California appealed a decision regarding its reporting of patient days for the purpose of calculating Medi-Cal reimbursement. The controversy centered around whether "bed hold" days — days when a patient is not physically in the hospital's subacute section but is expected to return — should be included in the reported patient days. If these days were included, it would result in a smaller per diem reimbursement to the hospital by the state. The hospital argued that bed hold days should be excluded, pointing to the Accounting and Reporting Manual for California Hospitals (the "Hospital Manual"), which does not specifically mention bed holds. The state, on the other hand, referred to the Accounting and Reporting Manual for California Long-Term Care Facilities (the "Long-Term Manual"), which specifically states that bed hold days should be included in total patient days.
The Court of Appeal of the State of California, Second Appellate District, Division Eight ruled in favor of the state, affirming the lower court's decision. The court held that where two state manuals guide health care facility accounting, the one that specifically addresses the issue at hand — in this case, the Long-Term Manual's explicit reference to bed holds — governs. The court reasoned that the specific provision controls the general one and can be regarded as a correction to it. Thus, according to this holding, Gardena Hospital must include bed hold days in its reported patient days for the calculation of Medi-Cal reimbursement.
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