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Hinds v. Blue Cross and Blue Shield of Tenn., Inc.
No. 3:95-0508 (M.D. Tenn. Dec. 28, 1995). ; Clearinghouse Number: 50704
Description
Bowel and Liver Transplant for Three-Year-Old with Short-Bowel Syndrome Is a Covered Service Under Medicaid and TennCare
Abstract
Granting plaintiff’s motion for a preliminary injunction, the
district court has ordered defendant insurer to fund
plaintiff’s bowel and liver transplant. Plaintiff is a
three-year-old, Medicaid-eligible child who is enrolled in
TennCare, Tennessee’s Medicaid demonstration project.
Defendant insurer has contracted with the state to provide managed
health care services to Medicaid-eligible enrollees under the
demonstration project. Plaintiff suffers from short-bowel syndrome
and must undergo up to 13 hours daily of intravenous feeding in
order to survive. The intravenous feeding has caused liver damage,
and her doctors have recommended that she undergo a liver and bowel
transplant. Defendants, insurer and the Tennessee Department of
Health, which administers TennCare, refused to authorize funds for
the dual transplant because in their determination such treatment
was not covered under Medicaid law or the TennCare program. The
district court rejected the argument that, under 42 U.S.C. §
1396b(i), a state has complete discretion to determine which
transplants it will fund. The court also found that plaintiff was
likely to succeed on her claim that a small-bowel transplant was
not experimental but a medically necessary procedure and the only
one currently available to treat her condition; a bowel and liver
transplant was a covered service under the TennCare risk agreement
in plaintiff’s case because it was nonexperimental, medically
necessary, performed within accepted modes of treatment, and
cost-effective. However, the court rejected plaintiff’s claim
that defendant insurer misled her into believing that it would
cover transplant services in violation of the state’s
consumer protection act.
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