Articles Posted in Public Benefits

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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

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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

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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

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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

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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

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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