Linton v. Carney - 779 F. Supp. 925 (M.D. Tenn. 1990)

Rule:

Title XIX of the Social Security Act, 42 U.S.C.S. § 1396 et seq., authorizes the expenditure of federal funds to enable states to furnish medical assistance to indigent individuals who are aged, blind or disabled, or who are members of families with dependent children. Tennessee participates in Title XIX for the purpose of operating such a medical assistance program (Medicaid), pursuant to Tenn. Code Ann. § 71-5-101. In return for receipt of federal subsidies, the State of Tennessee is required to administer its Medicaid program in conformity with a state plan which satisfies the requirements of Title XIX and regulations promulgated pursuant thereto, and which has been submitted to, and approved by the Secretary of Health and Human Services. 42 U.S.C.S. §§ 1396, 1396a. 

Facts:

Plaintiffs, a group of indigent patients, are before the Court seeking to enjoin a Tennessee policy through which only a portion of the beds in Medicaid participating nursing homes are certified to be available for Medicaid patients. They alleged that this policy artificially limits the accessibility of nursing home care to indigent Medicaid patients and fosters discrimination against indigent patients by nursing homes. Plaintiffs claimed that, as a result of the challenged policy, they and other individuals similarly situated face delay or outright denial of needed nursing home care, as well as displacement from current residency in nursing home facilities. They brought this action under 29 U.S.C. § 794, the Rehabilitation Act of 1973; 42 U.S.C. § 1396 (Supp. 1987), et seq., Title XIX of the Social Security Act, and 42 U.S.C. § 2000d (1982 and Supp. 1987) et seq., Title VI of the Civil Rights Act of 1964, and the Due Process Clause of the Fourteenth Amendment.

Issue:

Was the limited bed certification policy of the Tennessee Medicaid program lawful?

Answer:

No

Conclusion:

The court found that the limited bed certification policy had caused widespread displacement of patients and that the group of indigent patients established by a preponderance of the evidence that the Tennessee Medicaid program had a disparate and adverse impact on minorities in violation of Title VI. The commissioner's explanation that the self-selection preferences of the minorities justified minority underrepresentation was not valid. The court held that the policy violated federal Medicaid statutes and various regulations relating to nursing home survey and certification. Tennessee's limited bed certification policy transformed the survey and certification process into an instrument for denying patients' access to the medically necessary care to which they were entitled.