Catanzano v. Wing

992 F. Supp. 593 (W.D.N.Y. 1998). ; Clearinghouse Number: 45058

Description

States May Require Home Health Agencies to Provide Care

Abstract

The district court ruled that Medicaid’s freedom-of-choice law, 42 U.S.C. § 1396a(a)(23), did not preclude a state from obligating home health care providers to give care. Medicaid recipients of home health care brought a class action suit after New York State amended its laws governing home health care to create a four-step process for certified home health agencies (CHHAS) to decide whether to provide services. The trial court halted the process, and the Second Circuit agreed but returned the case to the district court to determine whether federal law prohibited a state from requiring providers to give care against their will. The court, ruling in favor of plaintiff-appellee and other recipients, reasoned that the legislative history of the freedom-of-choice law indicated that Congress intended to confer a right upon recipients, not providers. It held that chhas act for the state in providing services to Medicaid recipients and that for CHHAS to refuse to fulfill a state’s obligation to give care would mean that states could effectively evade their obligation to give care by delegating to CHHAS.

Additional Information

Docket Date
1970-01-01 06:00:00+00:00