Community Health Care Assoc. of N.Y. v. Shah, No. 13-771 (2d Cir. 2014)Annotate this Case
Plaintiffs are health-service providers designated under federal law as Federally Qualified Health Centers (FQHC) and a trade association representing a number of FQHCs. Plaintiffs filed suit challenging New York's methods of reimbursing them for services they provide under Medicaid, seeking injunctive relief under 42 U.S.C. 1983. The district court upheld for the most part the Commissioner's methods for reimbursing FQHCs but granted prospective relief to plaintiffs for reimbursement for certain services they provide to patients enrolled with Medicaid Managed Care Organizations (MCOs). The court concluded that, as to the questions presented on appeal - with only one exception - there are no disputed issues of material fact, and that summary judgment was appropriate; the court agreed with the district court's approach to, and analysis of, the majority of the issues before the court; the court affirmed the grant of summary judgment to the Commissioner on most issues involving his methodologies for reimbursing FQHCs, and affirmed the grant of summary judgment to the FQHCs on issues involving their reimbursement for services provided to MCO enrollees; the court found that the district court erred in concluding that there were no disputed issues of material fact with respect to the Commissioner's methodology for calculating its prospective obligation to make a wraparound payment to FQHCs that provide services under a contract with an MCO; and the court vacated in limited part the district court's grant of summary judgment to the Commissioner and remanded for further proceedings.