Mississippi Division of Medicaid v. Women's Pavilion of South Mississippi, PLLC
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The case involves the Mississippi Division of Medicaid and the Women’s Pavilion of South Mississippi, PLLC. Women's Pavilion, a physician-owned OBGYN clinic, challenged Mississippi Division of Medicaid's calculation of the "encounter rate," a set amount of money per visit by a Medicaid patient. Medicaid set the clinic’s encounter rate at $157.94, which was partially based on the compensation of the five physician owners of the clinic.
Women’s Pavilion appealed this decision and requested an administrative hearing. The hearing officer evaluated whether Medicaid’s initial decision was supported by substantial evidence, affirming the reimbursement rate. However, Women’s Pavilion appealed again, arguing that the hearing officer applied the wrong standard of review.
The Hinds County Chancery Court agreed with Women’s Pavilion, holding that the hearing officer should have made his own findings of fact and determinations of the issues presented, rather than merely evaluating whether Medicaid’s initial decision was supported by substantial evidence. The court vacated Medicaid’s final decision and remanded the matter back to Medicaid.
The Mississippi Division of Medicaid appealed to the Supreme Court of Mississippi. The Supreme Court affirmed the decision of the Hinds County Chancery Court, stating that the hearing officer had erred by applying the standard of review for courts reviewing a final administrative decision, rather than following Medicaid’s own administrative rules governing provider appeals. The case was remanded back to Medicaid for further proceedings under the proper standard of review.
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