Smith v. Chattanooga Medical Investors, Inc.

No. E2000-01352-COA-R3-CV (Tenn. App. June 27, 2001) ; Clearinghouse Number: 53898

Description

Medicaid-Eligible Patient Denied Readmission to Nursing Facility Is Third-Party Beneficiary of Contract Between Provider and State

Abstract

Because defendant-appellee’s nursing facility breached its Medicaid contract with the state by failing to readmit plaintiff-appellant, damages may be awarded to plaintiff-appellant as a third-party beneficiary of the contract. Plaintiff-appellant, a paraplegic, had received Medicaid benefits until he became eligible for Medicare, limited to one hundred days. After admission to defendant-appellee’s facility as a Medicare patient, plaintiff-appellant needed urgent medical care and was transferred to a hospital. When defendant-appellee refused to readmit him upon discharge, plaintiff-appellant brought an action for breach of contract, which the trial court dismissed. Reviewing de novo, the court of appeals rejected defendant-appellee’s argument that it had no duty to readmit because plaintiff-appellant was not “medically entitled” to Medicaid-reimbursed care since the preadmission evaluation the state regulation required had expired. The court found plaintiff-appellant to be “Medicaid eligible” under state regulations and a third-party beneficiary of the provider agreement between the state and defendant-appellee’s facility. The court held that the contract required defendant-appellee to comply with all state and federal rules and regulations governing the readmission of a patient after the patient’s transfer to a hospital for urgent medical care.

Additional Information

Attorney Information
Docket Date
2001-06-27 00:00:00+00:00

Files

Filed under: