Select Specialty Hospital v. Brentwood Hutterian, Brethren, No. 22-3121 (8th Cir. 2023)
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After suffering a stroke, Mary, a member of the Brentwood Hutterite Brethren, received care at a Select Specialty Hospital. During her time at Select, she was covered by Brentwood’s insurance. But after Mary applied for and received Medicaid, it retroactively covered her time at Select. Select accepted $300,000 from Medicaid for Mary’s care—far less than it was expecting from Mary’s Brentwood insurance. Select sought payment from Brentwood, the Hutterite Brethren General Fund (the Fund), and South Dakota Medical Holdings Company (Dakotacare) for breach of contract. It also sought damages from Brentwood and the Fund for fraud and deceit. The district court granted summary judgment to Brentwood, the Fund, and Dakotacare. On appeal, Select argues that Brentwood and the Fund breached their contractual obligations by refusing to pay for Mary’s treatment.
The Eighth Circuit affirmed. The court explained that Select has already accepted money from Medicaid “as payment in full” for Mary’s care. Under 42 C.F.R. Section 447.15, “the Medicaid agency must limit participation in the Medicaid program to providers who accept, as payment in full, the amounts paid by the agency.” The court wrote that as a Medicaid program participant, Select must follow this regulation. The central issue here is whether Section 447.15’s “payment in full” provision bars Select from pursuing third parties like Brentwood and the Fund after accepting payment from Medicaid. The court wrote that in its view, Section 447.15’s “payment in full” language is plain and unambiguous: Once Select accepted payment from Medicaid, it was paid in full for Mary’s care.
Court Description: [Kobes, Author, with Benton and Erickson, Circuit Judges] Civil case - Contracts. Under 42 C.F.R. Sec. 447.15, Select, as a Medicaid program participant, was barred from pursuing additional reimbursement from third parties after it accepted payment in full from Medicaid for the care of a covered patient; grant of summary judgment for defendant on Select's breach of contract claim against defendant Dakotacare affirmed; grant of summary judgment on Select's fraud and deceit claims against defendants Brentwood and the General Medical Fund affirmed. [ August 29, 2023 ]
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