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Keywords

lawsuitplaintiffstatuteregulation
plaintiffdefendantstatuteappealsummary judgmentregulationappellantappellee

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Skubel v. Fuoroli, 113 F.3d 330, 65 USLW 2751, 53 Soc.Sec.Rep.Serv. 368, Med & Med GD (CCH) P 44,236

Facts

The plaintiffs, Jacinta Skubel and Travis Hardy, are children with severe medical conditions requiring constant nursing care. Skubel, aged eight, suffers from multiple serious disorders, necessitating 76 hours of nursing care per week, while Hardy, aged twelve, requires 40 hours of nursing care. Both children were denied Medicaid funding for nursing services outside their homes due to a regulation restricting such services to the recipient's residence. The plaintiffs filed a lawsuit after exhausting attempts to seek clarification on the regulation from the Health Care Financing Administration.

Plaintiffs are children suffering from severe medical conditions who require nearly constant supervision during their waking hours.

Issue

Whether the regulation limiting Medicaid-funded home health care services to services provided only at the recipient's residence is a reasonable interpretation of the Medicaid statute.

the regulation limiting Medicaid-funded home health care services to services provided only at recipient's residence was unreasonable interpretation of Medicaid statute.

Rule

The court applied the Chevron two-step analysis to determine if the agency's interpretation of the statute was reasonable, considering whether Congress had clearly expressed its intent on the issue.

we employ the two-step analysis enunciated in Chevron, U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837, 842–43, 104 S.Ct. 2778, 2780–81, 81 L.Ed.2d 694 (1984).

Analysis

The court found that the Medicaid statute was ambiguous regarding the location of home health care services. It determined that the regulation's restriction to services provided at home was not a reasonable interpretation, as it ignored medical advances that allow disabled individuals to access community services. The court noted that the regulation lacked a rational connection to the statute's purpose and did not reflect current medical practices.

the restriction ignores the consensus among health care professionals that community access is not only possible but desirable for disabled individuals.

Conclusion

The court affirmed the district court's judgment, modifying it to limit Medicaid-covered home health nursing services to the number of hours to which recipients would be entitled if the services were provided exclusively at their residence.

the judgment of the district court is affirmed but modified to expressly limit recipients of Medicaid-covered home health nursing services to the number of hours of service to which they would be entitled if the services were provided exclusively at the recipient's place of residence.

Who won?

The plaintiffs, Jacinta Skubel and Travis Hardy, prevailed because the court found the regulation limiting Medicaid coverage to home services to be an unreasonable interpretation of the Medicaid statute.

Defendants-appellants Joyce Thomas and Julie Pollard, in their respective official capacities as Commissioner and Director of Medical Administrative Operations of the Connecticut Department of Social Services (“DSS”), appeal from a judgment entered in the United States District Court for the District of Connecticut (Burns, J.) granting summary judgment in favor of plaintiffs-appellees Jacinta Skubel and Travis Hardy.

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