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St. Luke's Magic Valley Regional v. Board of County Commissioners

February 2, 2011

ST. LUKE'S MAGIC VALLEY REGIONAL MEDICAL CENTER, LTD, AN IDAHO NONPROFIT CORPORATION, PETITIONER-APPELLANT,
v.
BOARD OF COUNTY COMMISSIONERS OF GOODING COUNTY, RESPONDENT.



Appeal from the District Court of the Fifth Judicial District of the State of Idaho, Gooding County. The Honorable R. Barry Wood, District Judge.

The opinion of the court was delivered by: J. Jones, Justice.

2010 Opinion No. 6

St. Luke's Magic Valley Regional Medical Center appeals the district court's decision affirming Gooding County's denial of its application for medical indigency assistance on behalf of Maria del Carmen Perez. We vacate the judgment of the district court and remand for further proceedings.

I.

Factual and Procedural Background

Maria del Carmen Perez received emergency medical treatment at St. Luke's from June 17, 2008, through June 19, 2008. At that time, she was an undocumented alien living in Gooding County, Idaho. As a result of her medical treatment, Perez incurred medical expenses in excess of $11,000. St. Luke's timely filed an application with Gooding County (County) seeking county indigency assistance for payment of Perez's medical expenses pursuant to title 31, chapter 35 of the Idaho Code (Medical Indigency Act). On August 11, 2008, the Gooding County Board of Commissioners (Board) denied the application on the ground that St. Luke's could seek federal funding under Section 1011 of the Medicare Modernization Act of 2003 (MMA), which is a federal program that offers payment to participating hospitals for emergency medical treatment provided to undocumented aliens.*fn1 The Board also determined that Perez was not medically indigent because she and her significant other had sufficient discretionary income available to make payments toward her medical expenses. St. Luke's appealed the initial denial of the application, and the Board held a hearing on October 16, 2008. Following the hearing, the Board again denied the application on the ground that Section 1011 funding was a resource available to St. Luke's for reimbursement of Perez's medical expenses. The Board's final decision did not involve a determination that Perez was not medically indigent. Following review by the pre- litigation screening panel, St. Luke's filed a petition for judicial review with the district court. The district court upheld the denial of the application, concluding that the Board properly considered St. Luke's ability to obtain payment for Perez's medical expenses under Section 1011 in determining that Perez was not medically indigent. St. Luke's timely appealed to this Court.

On appeal, St. Luke's argues that the Board erred in determining that Section 1011 was an available resource for the payment of Perez's medical expenses because the rules governing the Section 1011 program require a hospital to seek reimbursement from state indigency programs prior to requesting Section 1011 assistance. St. Luke's further asserts that Section 1011 funding should not be considered when determining whether Perez is medically indigent because St. Luke's is eligible for Section 1011 payment, not Perez, and only resources available to the patient are relevant when determining medical indigency.

The County, on the other hand, argues that while a hospital must seek all available resources prior to requesting Section 1011 funding, the federal rules expressly exempt hospitals from the duty to seek payment from state indigent programs prior to seeking Section 1011 assistance. The County also argues that because St. Luke's would be requesting Section 1011 assistance to cover Perez's medical expenses, St. Luke's and Perez have an "identity of interest," and it is irrelevant that Perez cannot personally apply for Section 1011 funding. Both parties request attorney fees on appeal.

II.

Issues on Appeal

I. Whether the Board erred in denying St. Luke's application for indigency assistance on the ground that federal assistance under Section 1011 of the Medicare Modernization Act of 2003 was an available resource.

II. Whether either party is entitled to attorney fees on appeal.

III.

Standard of ...


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