Justia Health Law Opinion Summaries

Dr. Adolfo P. Morales sued Jackson HMA, LLC., d/b/a Central Mississippi Medical Center (Jackson HMA) for breach of contract. A jury awarded Morales substantial damages. Jackson HMA filed a "Motion for Judgment Notwithstanding the Verdict, and, in the alternative, For a New Trial" and a "Motion for Amendment of Judgment." The Circuit Court denied the post-trial motions and Jackson HMA filed this appeal. In 2004, a recruiter for Jacksom HMA sent Morales a "letter of intent" outlining Jackson HMA's proposed offer. The letter twice stated that the proposed offer required "preapproval" by "Corporate" (HMA). Although not requested or provided for, Morales signed and returned the letter. On it he wrote "I agree to all and accept the terms of your offer." At trial, Morales acknowledged that this letter was not a contract, as it "no doubt" required preapproval from the corporate office. Subsequently, Jackson HMA sought approval from corporate HMA, but corporate did not approve the terms. Jackson HMA's CEO impressed upon corporate the need for an ophthalmologist and suggested new terms to corporate which reduced the guaranteed amount and period by half. The CEO received approval of these reduced terms from an HMA vice-president for the eastern part of the United States. Thereafter, the recruiter sent Morales a second letter detailing the new "terms of our offer" which reflected the reduced guarantees approved by corporate HMA. The letter lacked the phrase "letter of intent" and also made no reference to a requirement of corporate approval of the terms. The letter included the language, "[b]y signing and returning this letter, you will confirm your commitment to entering into a contractual agreement . . . . Accordingly we will begin the process of assimilating contract documents for your review." Morales signed the document, but approval never arrived. In early March 2005, the recruiter informed Morales that the contract had not been approved. In late 2005, Morales filed suit alleging that Jackson HMA had breached its contract with him. The jury returned a verdict in favor of Morales. Jackson HMA appealed. After its review, the Supreme Court concluded that Morales presented sufficient evidence for the jury to find that a contract existed. However, Morales presented insufficient evidence to support the jury's damages award. The Court affirmed the judgment for Dr. Morales, but reversed on the issue of damages and remanded this case to the Circuit Court for a new trial solely on damages. View "Jackson HMA, LLC v. Morales" on Justia Law

Beckley Appalachian Regional Hospital (Beckley ARH) was a voluntary provider of medical services through the Medicaid program pursuant to an agreement executed between it and the West Virginia Bureau for Medical Services (BMS). Beckley ARH filed a lawsuit against the West Virginia Department of Health and Human Resources and its secretary and the BMS and its commissioner (collectively, Respondents), seeking a remedy for inadequate Medicaid reimbursement rates. The circuit court dismissed the complaint for failure to state a claim upon which relief could be granted. The Supreme Court affirmed, holding that W. Va. Code 9-15-16 and 16-29B-20 do not provide for an express or implied private cause of action by a Medicaid provider for judicial review of reimbursement rates for medical services.View "Appalachian Reg'l Healthcare v. W. Va. Dep't of Health & Human Res." on Justia Law

This case involved L.A., who suffered from schizophrenia. Following her release from her previous commitment, the State filed a petition for involuntary commitment of L.A. After a trial, the jury concluded by special verdict that L.A. was suffering from a mental disorder, was unable to provide for her basic needs, and was a threat of injury to herself or others. The jury also found that if L.A.'s condition were left untreated, it would deteriorate. Following the verdict, the district court adopted an order of commitment and transport order prepared by the State that committed L.A. to the state hospital and approved involuntary medication if it was deemed necessary. The Supreme Court affirmed, holding that the district court did not err by (1) failing to make a detailed statement of facts in its post-trial disposition order; and (2) failing to detail the particular evidence upon which its findings and conclusions were based in authorizing L.A's involuntary medication.View "In re L.A." on Justia Law

Appellee Steven Wilson is a licensed optometrist, providing eye care services in Lowndes County as Wilson Eye Center (“WEC”). Appellees Cynthia McMurray, Jodie E. Summers, and David Price are also licensed optometrists employed by WEC. Prior to 2010, Spectera, Inc. had entered provider contracts ("Patriot contracts") with Wilson and McMurray and they became members of Spectera's panel of eye care providers. Summers was already on Spectera's panel of eye care providers. Under the Patriot contract, Spectera would reimburse appellees for the materials Spectera insureds used from WEC's inventory by paying appellees a fee for their materials' costs and by having Spectera insureds remit a materials copayment to appellees. Spectera decided to terminate its Patriot contracts and replace them with independent participating provider (IPP) agreements. After the trial court temporarily enjoined Spectera from enforcing its IPP agreement, Spectera sought to remove appellees Wilson, Summers, and McMurray from its approved panel of providers. The trial court enjoined Spectera from taking such action. Although Price was not on Spectera's provider panel, he alleged Spectera violated Georgia law by denying him membership on its panel because of his refusal to sign the IPP agreement. Upon considering the parties' cross motions for summary judgment, the trial court granted issued a permanent injunction precluding Spectera from enforcing the restrictions contained in the IPP agreement as to "any other licensed eye care provider on [Spectera's] provider panel" or those who had applied for admittance to the panel. Spectera appealed the trial court's decision to the Court of Appeals which affirmed in part and reversed in part. Upon review of Spectera's appeal, the Supreme Court concluded a portion of the IPP agreement violated Georgia law, and therefore sustained the Court of Appeals in one respect. However, because the IPP agreement did create the type of impermissible discrimination between classes of licensed eye care providers contemplated by the applicable law, the Court of Appeals was incorrect in concluding that the IPP agreement violated that particular subsection of the applicable law. Furthermore, the termination of any outstanding contracts with appellees Wilson, McMurray, and Summers should have been based on the lawful terms stated in the contracts and not based on a permanent court injunction. Therefore, the Supreme Court affirmed in part, reversed in part and remanded the case for further proceedings.View "Spectera, Inc. v. Wilson" on Justia Law

Comprehensive Home Health Services filed a certificate of need (CON) with the Cabinet for Health and Family Services to expand its home health services into Whitley County. Two Existing Providers requested a hearing to oppose the application. The hearing officer approved of the CON after disallowing certain evidence proffered by the Existing Providers. The circuit court reversed, finding that the Cabinet's decision to grant the CON was arbitrary and ruling that the evidence allowed at the remand hearing should be "limited to the scope of the October 25, 2006 hearing." The Existing Providers appealed, contending that the circuit court's order would limit the evidence on remand to an outdated state health plan (SHP). The court of appeals reversed, concluding that the current SHP, not the one in place at the time of the original hearing, must guide the decision on remand. The Supreme Court affirmed, holding (1) allowing consideration of changed circumstances and the current SHP on remand was not contrary to principles of administrative law and fulfilled the purpose of the CON statute; and (2) the court of appeals properly interpreted CON statutes and regulations to require consideration of the current SHP and calculations.View "Comprehensive Home Health Servs., Inc. v. Prof'l Home Health Care Agency, Inc." on Justia Law

The Office of the Medicaid Inspector General (OMIG) terminated a physician's participation in the Medicaid program on the basis of a Bureau of Professional Medical Conduct (BPMC) consent order, in which the physician pleaded no contest to charges of professional misconduct and agreed to probation. Supreme Court annulled the OMIG's determination. The Appellate Division affirmed, concluding (1) the agency acted arbitrarily and capriciously in barring the physician from treating Medicaid patients when the BPMC permitted him to continue to practice; and (2) the OMIG was required to conduct an independent investigation before excluding a physician from Medicaid on the basis of a BPMC consent order. The Court of Appeals affirmed but for another reason, holding (1) the OMIG is authorized to remove a physician from Medicaid in reliance solely on a consent order between the physician and the BMPC, regardless of whether BPMC chooses to suspend the physician's license or OMIG conducts an independent investigation; but (2) because OMIG did not explain why the BPMC consent order caused it to exclude the physician from the Medicaid program, the agency's determination was arbitrary and capricious.View "Koch v. Sheehan" on Justia Law