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In re L.
(Conn. Dep’t of Soc. Servs. Office of Admin. Hearings & App. filed Sept. 17, 1998). ; Clearinghouse Number: 52282
Description
Nursing Home Resident Admitted for Respite Care During Her Caregiver’s Hospitalization May Not Be Discharged Absent Written Notice
Abstract
The fair hearing officer held that respondent nursing home, in
attempting to discharge petitioner, failed to comply with the state
nursing home discharge law (based on 42 U.S.C. § 1396r and
implementing regulations). Petitioner, who has Alzheimer’s
disease, was admitted to the nursing home for respite care while
her husband was in the hospital with pneumonia. After
petitioner’s husband was released from the hospital, nursing
home sought to discharge petitioner without written notice.
However, petitioner’s husband felt too weak to care for his
wife and refused to pick her up. The regional ombudsman and legal
services were contacted, and nursing home eventually agreed to
issue a written discharge notice. However, nursing home took the
position that the discharge law did not apply because petitioner
was not a "resident" since she had been admitted pursuant
to regulations that were exceptions to the first-come, first-served
state wait list law. The hearing officer found that, even though
petitioner was initially admitted for respite care, she was a
"resident" and therefore subject to the state discharge
rules. The hearing officer also found that nursing home failed to
comply with the law because (1) it did not give the notice at least
ten days before the proposed discharge; (2) two of the reasons for
discharge cited in the notice were not permissible under state law;
and (3) the third reason cited in the notice was not proven because
nursing home never determined whether it could meet
petitioner’s needs.
