Medicaid

Medicaid: A Joint Federal-State Program

In Wilder v. Virginia Hospital Assn., 496 U.S. 498 (1990), the Supreme Court stated:

Medicaid is a cooperative federal-state program through which the Federal Government provides financial assistance to States so that they may furnish medical care to needy individuals. § 1396. Although participation in the program is voluntary, participating States must comply with certain requirements imposed by the Act and regulations promulgated by the Secretary of Health and Human Services (Secretary). To qualify for federal assistance, a State must submit to the Secretary and have approved a “plan for medical assistance,” § 1396a(a), that contains a comprehensive statement describing the nature and scope of the State’s Medicaid program. 42 CFR § 430.10 (1989). The state plan is required to establish, among other things, a scheme for reimbursing health care providers for the medical services provided to needy individuals.

Section 1902(a)(13) of the Act sets out the requirements for reimbursement of health care providers. As amended in 1980 (Boren Amendment), the section provides that

“a State plan for medical assistance must —
…..
“provide . . . for payment . . . of the hospital services, nursing facility services, and services in an intermediate care facility for the mentally retarded provided under the plan through the use of rates (determined in accordance with methods and standards developed by the State. . .) which the State finds, and makes assurances satisfactory to the Secretary, are reasonable and adequate to meet the costs which must be incurred by efficiently and economically operated facilities in order to provide care and services in conformity with applicable State and Federal laws, regulations, and quality and safety standards and to assure that individuals eligible for medical assistance have reasonable access . . . to inpatient hospital services of adequate quality.” 42 U. S. C. § 1396a(a) (13)(A) (1982 ed., Supp. V) (emphasis added).

In Cook v. Glover, 295 Ga. 495 (2014), the Georgia Supreme Court stated:

Medicaid is a joint federal-state program that provides medical care to needy individuals. See Douglas v. Independent Living Center of Southern California, Inc., 565 U.S. 606, 132 S. Ct. 1204, 182 L.Ed.2d 101 (2012). As a participant in the Medicaid program, the State of Georgia is required to have an approved state plan for medical assistance which complies with certain requirements imposed by the Medicaid Act as well as with regulations promulgated by the Secretary of Health and Human Services. See Wilder v. Virginia Hosp. Ass’n., 496 U.S. 498, 502, 110 S. Ct. 2510, 110 L.Ed.2d 455 (1990); 42 U.S.C. § 1396a (a). As federal administrator of the Medicaid program, CMS is responsible for the approval of state Medicaid plans and for providing statutory interpretation and guidance with respect to Medicaid eligibility and the penalties for noncompliance with Medicaid rules.[3] See Douglas, supra, 132 S. Ct. at 1208.

In United Cerebral Palsy of Georgia v. Ga. Dep’t of Behavioral Health and Dev. Disabilities, 331 Ga. App. 616 (2015), the Court of Appeals stated:

Medicaid is a cooperative federal-state program through which the federal government furnishes financial assistance to the states so that the states may provide necessary medical, rehabilitation, and other services to low-income persons.” Prado-Steiman v. Bush, 221 F.3d 1266, 1268(I)(a) (11th Cir.2000). Although participation in the program is voluntary, states that choose to participate must develop and have approved by the federal government a state Medicaid plan that complies with the requirements of the Medicaid Act. Wilder v. Virginia Hosp. Assn., 496 U.S. 498, 502(I)(A), 110 S. Ct. 2510, 110 L.Ed.2d 455 (1990). With federal approval, states may enact waiver programs that exempt them from certain otherwise-mandated federal Medicaid requirements. 42 USC § 1396n (b)

Published by
David McGuffey

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