7 F. Supp. 3d 641
M.D. La.2013Background
- On April 20, 2008, Louisiana DHH enacted internal regulation LAC 50:1.8341 et seq. restricting Medicaid payor methods.
- On November 20, 2008, Taylor was injured and treated at UMC in Lafayette, incurring a bill of $2,579.40.
- DHH paid $1,574.02 of Taylor’s bill with Medicaid funds, leaving a balance of $1,005.38.
- Taylor settled his third-party tort claim for $10,000.
- LSU Health System asserted a lien for $1,005.38 against Taylor.
- Court grants partial summary judgment finding state regs preempted by federal Medicaid law to the extent they permit recovery of the balance from third-party proceeds after Medicaid payment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Louisiana DHH regs are preempted by federal Medicaid law | Taylor argues direct conflict between state regs and federal law | DHH argues no preemption or that regs do not conflict in practice | Yes; DHH regs are preempted to the extent they permit balance recovery after Medicaid payment |
Key Cases Cited
- Matter of Cajun Elec. Power Coop., Inc., 109 F.3d 248 (5th Cir.1997) (conflict when compliance with federal and state regs is impossible or impedes congressional objectives)
- Florida Lime & Avocado Growers, Inc. v. Paul, 373 U.S. 132 (Supreme Court 1963) (conflict preemption principle relevant to implied field preemption)
- Miller v. Gorski Wladyslaw Estate, 547 F.3d 273 (5th Cir.2008) (Medicaid does not allow providers to recover more than program reimbursement; lien contexts limited)
- Spectrum Health Continuing Care Group v. Bowling, 410 F.3d 304 (6th Cir.2005) (support that providers cannot exceed Medicaid reimbursement when patient is covered)
- Evanston Hosp. v. Hauck, 1 F.3d 540 (7th Cir.1993) (provider cannot recover beyond Medicaid reimbursement when patient is covered)
- Lizer v. Eagle Air Med Corp., 308 F.Supp.2d 1006 (D.Ariz.2004) (state lien statute preempted; provider cannot recover balance after Medicaid funds)