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Bristol v. Rhode Island Dep’t of Human Services
Nos. 95-6605 (R.I. Super. Ct. Jan. 30, 1997). ; Clearinghouse Number: 51599
Description
Agency’s Exclusion of Medical Assistance Coverage for Incontinence Supplies Prescribed by Physician Is Reversed
Abstract
The court has reversed the Rhode Island Department of Health and
Human Services (DHS) decisions denying Medical Assistance coverage
of adult diapers needed by incontinent plaintiffs and prescribed by
their physicians. DHS regulations explicitly excluded coverage of
adult diapers under the "durable medical equipment"
category. The court ruled that the supplies fell within the
category "rehabilitation services" included under the
federal definition of "optional categories of service"
under 42 U.S.C. § 1396d(a)(13). The court noted that the
blanket exclusion of adult diapers was an unreasonable standard and
therefore contrary to 42 U.S.C. § 1396(a)(17) and held that
blanket exclusion was arbitrary and capricious in that it excluded
coverage of services without regard to medical need and without due
deference to treating physician opinions.
