In re Surveillance & Integrity Review Appeals by Trinity Home Health Care Services
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The Supreme Court reversed the decision of the court of appeals affirming the final order of the Commissioner of the Department of Human Services' (DHS) concluding that Trinity had engaged in the abuse outlined in DHS's notices and spreadsheets, holding that the first report of the administrative law judge (ALJ) was the binding decision in this matter.
Trinity Home Health Care, which provided nursing and personal care assistant services, received reimbursement from DHS for services that it provided to Medicaid-eligible people with disabilities. After an investigation, DHS sent Trinity notices of termination from the program and demanding return of overpayments and payment-withholding. Both before and after remand by the Commissioner, the ALJ found that terminating Trinity's participation in the Minnesota Health Care Programs was an inappropriate sanction for Trinity's failure to provide certain records. The Commissioner modified the report, concluding that Trinity had engaged in the abuse alleged by the DHS. The court of appeals affirmed. The Supreme Court reversed, holding (1) the Commissioner did not have the authority to remand the case due to the DHS's general authority to administer and supervise Medicaid; and (2) the Commissioner did not have implied authority to remand the case to the ALJ under case law.
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