Samantha A. v. Department of Social & Health Services, 171 Wash. 2d 623

Samantha A. is a child with extensive medical needs and is enrolled in Medicaid Home and Community Based Waiver with in-home Medicaid personal care (MPC).
DSHS enacted WAC 388-106-0213 in 2005 to automatically reduce a child’s base MPC hours based on age and whether the child lives with a parent.
Samantha’s CARE assessment initially determined 90 MPC hours; under 0213 this was reduced to 39 hours.
A medical provider recommended 96 MPC hours under EPSDT, but DSHS did not increase hours or grant an ETR hearing.
The superior court found WAC 0213 violated federal Medicaid comparability and EPSDT requirements; it invalidated WAC 0213 and the enabling provision WAC 388-106-0130(3)(b), and awarded Samantha attorney fees.
The Washington Supreme Court partly affirmed, invalidating WAC 0213 and its enabling provision, and upheld the attorney-fee award; it declined to reach other issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does WAC 388-106-0213 violate federal Medicaid comparability?	Samantha A. argues the rule impermissibly reduces hours without individualized need.	DSHS contends the rule reflects developmental needs and parental roles, within allowable utilization control.	Yes; WAC 0213 violates federal comparability.
Whether the superior court properly awarded attorney fees under RCW 74.08.080.	Respondents seek fees because they prevailed.	DSHS argues EAJA should cap fees.	upheld; reasonable attorney fees awarded to Samantha.

Jenkins v. Department of Social & Health Services, 160 Wn.2d 287 (2007) (invalidated automatic reductions not tied to individualized need under comparability)
S.A.H. ex rel. S.J.H. v. Dep’t of Soc. & Health Servs., 136 Wn. App. 342 (2006) ( Medically assisted programs managed under Medicaid in Washington; comparability context)