Justia Government & Administrative Law Opinion Summaries

This appeal involved a putative class action filed by three Pennsylvania Medicaid beneficiaries subject to the Pennsylvania Department of Public Welfare's (DPW) liens against future settlements or judgments. At issue was whether state agencies responsible for administering the Medicaid program have the authority to assert such liens and, if so, whether Pennsylvania's statutory framework was consistent with the Supreme Court's decision in Arkansas Department of Health and Human Services v. Ahlborn. The court examined the text, structure, history, and purpose of the Social Security Act, 42 U.S.C. 301 et seq., and held that liens limited to medical costs were not prohibited by the anti-lien and anti-recovery provisions of the Act, 42 U.S.C. 1396p(a)-(b). Accordingly, the court upheld Pennsylvania's longstanding practice of imposing such liens. The court also held that Pennsylvania's current statutory framework, which afforded Medicaid recipients a right of appeal from the default allocation, was a permissible default apportionment scheme.

The State provided prisoner Dewell Pearce extensive medical care during his incarceration. Around the time of his release from custody, Mr. Pearce won a medical malpractice judgment against the State. The State paid part of the judgment, but relying on a reimbursement statute, withheld the medical care costs associated with conditions unrelated to the malpractice claim. The State then sought a declaratory judgment that it was entitled to reimbursement from Mr. Pearce for treatment of the unrelated conditions. The superior court ruled that the statute in question did not authorize the State to seek reimbursement from former prisoners no longer in custody. The State appealed. Upon review of the superior court record and the applicable statute, the Supreme Court found that the superior court misinterpreted the law. The Court reversed the superior court's ruling and vacated the judgment. The Court remanded the case for further proceedings.

The West Virginia Medical Imaging & Radiation Therapy Technology Board of Examiners appealed an order of the circuit court. In the order, the court reversed the Board's decision to suspend Appellee Kenneth Harrison's medical license. The Board issued a final administrative decision that found Dr. Harrison practiced outside the scope of his medical imaging and radiation therapy license when he administered intravenous allergy medicine to a patient without the treating physician's involvement. Upon careful consideration of the arguments and the applicable legal authority, the Supreme Court reversed the lower court's decision.