Justia Iowa Supreme Court Opinion SummariesArticles Posted in Public Benefits
Colwell v. MCNA Insurance Co.
The Supreme Court affirmed the ruling of the district court against Defendant and in favor of Plaintiff finding breach of contract and breach of implied covenant of good faith and fair dealing, holding that the district court erred.Defendant, a managed care organization, entered into a contract with Plaintiff, a dentist, to deliver dental services to Medicaid participants as a member of Defendant's network. Defendant later sent Plaintiff a "notice of non-renewal" of the provider contract. Plaintiff sued, and the district court ruled that the provider contract did not allow Defendant to terminate Plaintiff through non-renewal of the provider contract. At issue was whether Defendant properly ended a provider contract that automatically renewed for successive one-year terms by sending a notice of non-renewal. The Supreme Court affirmed, holding that the district court correctly determined that Defendant possessed no right to terminate by non-renewal. View "Colwell v. MCNA Insurance Co." on Justia Law
Cox v. Iowa Department of Human Services
The Supreme Court affirmed the judgment of the district court affirming the position of the Iowa Department of Human Services (DHS) determining that transfers made by Petitioners, nursing home residents, to a pooled special needs trust were for less than fair market value and required a delay in Petitioners’ eligibility for Medicaid benefits, holding that the district court and DHS correctly construed and applied federal law requiring the delay in Medicaid benefits for long-term institutional care.Federal eligibility requirements provide that state ensure that Medicaid benefits are reserved for persons who lack financial means and have not transferred personal asserts that could pay for their care. Petitioners, at age sixty-five, transferred more than one-half million dollars to a pooled special needs trust. The Supreme Court held that the district court and DHS properly interpreted federal law effectively requiring Petitioner’s to tap their pooled trust assets first to pay for their nursing home care. View "Cox v. Iowa Department of Human Services" on Justia Law
Iowa Dep’t of Human Servs. v. Morse Healthcare Servs., Inc.
This case was the companion interlocutory appeal with facts that mirrored Iowa Dep’t of Human Servs. v. DeWitt Bank and Trust Co., decided on the day of this opinion. As in DeWitt Bank, the Iowa Department of Human Services filed an application for relief against defendant healthcare providers under Iowa Code 249A.44. The district court appointed a receiver. Bank Iowa, a lender that held perfected security interests in Defendants’ property, intervened and challenged the receiver’s applications for fees and expenses. The district court concluded that receivership expenses should be paid out of property in which the Bank had prior lien interests. The Supreme Court reversed based on the reasoning set forth in DeWitt Bank, holding that Iowa follows the common law rule that a receiver may be charged against a third party’s security interest only to the extent the secured creditor has received a benefit from the receivership or the secured creditor has consented to the receivership. Remanded. View "Iowa Dep’t of Human Servs. v. Morse Healthcare Servs., Inc." on Justia Law
Iowa Dep’t of Human Servs. v. Cmty. Care, Inc.
DeWitt Bank & Trust Company (Bank) held perfected security interests on real and personal property of Community Care, Inc. (CCI). When the Iowa Department of Human Services (DHS) determined that CCI had committed Medicaid fraud, DHS filed an application for injunctive relief under Iowa Code 249A.44. The district court enjoined CCI from transferring property or taking action inconsistent with DHS’s right to recover overpayments of medical assistance from CCI. CCI subsequently ceased operations, and the district court appointed a receiver for CCI. The Bank sought clarification that the receiver’s fees and expenses would not be paid out of CCI assets in which the Bank had a prior perfected security lien. The district court denied substantive relief, concluding that Iowa law requires the expenses of the receiver to be paid before secured creditors. The Supreme Court reversed, holding (1) Iowa law does not authorize a receiver to be paid out of assets that are subject to a prior perfected line; and (2) rather, Iowa follows the common law rule that the costs of a receiver may be charged against a third party’s security interest only to the extent the secured creditor has received a benefit from the receivership or the secured creditor has consented to the receivership. View "Iowa Dep’t of Human Servs. v. Cmty. Care, Inc." on Justia Law
Sunrise Ret. Cmty. v. Iowa Dep’t of Human Servs.
Plaintiffs, several nursing homes approved by the Iowa Department of Human Services (DHS) as Medicaid providers, submitted annual reports disclosing their income and expenses to DHS. DHS used the reports to calculate the Medicaid per diem reimbursement rates for the nursing homes. Some of the facilities' expenses were disallowed by DHS, and DHS reduced reimbursement rates accordingly. The facilities appealed the adjustments. The director of human services upheld the action. The district court affirmed. The court of appeals reversed, concluding that the DHS rules did not support its decision that the disputed costs were not allowable. The Supreme Court affirmed, holding that DHS's exclusion of the facilities' lab, x-ray, and prescription drug costs from the nursing homes' reports was based on an incorrect interpretation of its rules.View "Sunrise Ret. Cmty. v. Iowa Dep't of Human Servs." on Justia Law
In re Estate of Melby
Arnold and Vesta Melby were trustors of separate irrevocable trusts. Both Arnold and Vesta received Medicaid benefits. After the Melbys’ deaths, the Iowa Department of Human Services notified Arnold’s estate that it would seek reimbursement for all Medicaid expenses it had paid on behalf of Arnold and Vesta. The Department then filed an application in the estate seeking a judgment declaring the Melbys had interests in the corpus of their trusts that should be counted as assets available for repayment of the Department’s Medicaid claim. The district court concluded (1) the Melbys’ interests in the trusts were limited to their right to receive the net income from the trusts’ assets, and (2) the Department’s right to recover the Medicaid payments could be enforced against such income, but not against the corpus of the trusts. The Supreme Court reversed, holding (1) the Department’s right to recover Medicaid payments under the facts of this case extended beyond the Melbys’ net income interests; and (2) the district court erred in determining the scope of medical assistance for which recovery was authorized by the general assembly. Remanded. View "In re Estate of Melby" on Justia Law
Hall v. Employment Appeal Bd.
The Employment Appeal Board (Board) denied Willie Hall's application for unemployment insurance benefits. Hall filed a petition for judicial review. The district court affirmed the decision of the Board and assessed costs against Hall. The court of appeals affirmed. The Supreme Court reversed the portion of the judgment as it related to court costs, holding (1) pursuant to Iowa Code 96.15(2), any individual claiming benefits shall not be charged fees of any kind, including court costs, in a proceeding under the statute by a court or an officer of the court; and (2) therefore, the district court erred by requiring that Hall pay court costs. View "Hall v. Employment Appeal Bd." on Justia Law
Bowman v. City of Des Moines Mun. Hous. Agency
Krisha Bowman, a single mother of three minor children, received Section 8 housing assistance for several years. The Des Moines Municipal Housing Agency (DMMHA) later discontinued Bowman's housing assistance based on five alleged occurrences of unreported income. A hearing officer found that Bowman's assistance had been properly terminated. The district court affirmed. The Supreme Court affirmed, holding (1) DMMHA's determination that Bowman had five occurrences of unreported income was supported by substantial evidence; (2) DMMHA's policy of treating a failure to report each child's Social Security benefits as a separate occurrence of unreported income did not violate the Fair Housing Act; and (3) DMMHA did not improperly fail to consider Bowman's mitigating circumstances before terminating her assistance. View "Bowman v. City of Des Moines Mun. Hous. Agency" on Justia Law