AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• Princeton Place, a nursing home, admitted J.F., a resident with spina bifida, after conducting a Level I Preadmission Screening and Resident Review (PASARR) which concluded J.F. did not require a Level II evaluation. The New Mexico Human Services Department, Medical Assistance Division (HSD/MAD), later sought to recoup Medicaid payments made for J.F.'s care, arguing Princeton did not comply with preadmission screening regulations, specifically failing to refer J.F. for a Level II evaluation due to his condition (paras 6-16).

Procedural History

• District Court of Santa Fe County: Upheld HSD/MAD's decision to recoup Medicaid payments from Princeton, finding the preadmission screening was improperly performed (para 21).
• Court of Appeals of the State of New Mexico: Reversed the district court's decision, concluding Princeton complied with applicable preadmission regulations (para 37).

Parties' Submissions

• Petitioner-Appellant (Princeton Place): Argued that the administrative record demonstrated compliance with preadmission regulations and that the PASARR Form instructions did not have the force of law to serve as the basis for Medicaid recoupment (paras 24, 31-32).
• Respondent-Appellee (HSD/MAD): Contended that Princeton's failure to refer J.F. for a Level II evaluation constituted noncompliance with PASARR regulations, justifying the recoupment of Medicaid payments (paras 14-15).

Legal Issues

• Whether Princeton Place complied with the applicable preadmission screening regulations in its Level I PASARR screening of J.F. (para 24).
• Whether the instructions on the PASARR Form have the force of law to serve as the basis for Medicaid recoupment (para 28).

Disposition

• The Court of Appeals reversed the district court's decision, concluding that Princeton Place complied with all applicable PASARR regulations in its performance of J.F.'s preadmission screening (para 37).

Reasons

• The Court of Appeals, per Judge Michael E. Vigil, found that the PASARR Form and its instructions did not have the force of law and could not serve as the basis for the proposed Medicaid recoupment action against Princeton. The court reasoned that errors in completing the PASARR Form that do not violate properly promulgated PASARR rules or statutes cannot be deemed violations of law. Furthermore, the court concluded that Princeton's Level I PASARR screening of J.F. was performed correctly, as the instructions on the PASARR Form allowed discretion in referring individuals for Level II screening. The court also noted that the PASARR Form's instructions were inconsistent with federal PASARR regulations, contributing to regulatory uncertainty and potential conflict with federal standards. The case highlighted issues arising from the separation of responsibilities between DOH and HSD/MAD in overseeing the PASARR process and Medicaid payments (paras 28-36).