Appeals court rules against Florida in Medicaid payment dispute
A federal appeals court Tuesday sided with a Southwest Florida health-care provider in a years-long dispute with the state about payments for treating patients in the Medicaid program.
A three-judge panel of the 11th U.S. Circuit Court of Appeals upheld a district judge's decision in favor of Family Health Centers of Southwest Florida, which filed the lawsuit after the state Agency for Health Care Administration largely rejected a request for an increased Medicaid reimbursement rate.
The non-profit Family Health Centers is what is known as a federally qualified health center, with more than half of its patients in the Medicaid program, according to Tuesday's ruling. Generally, federally qualified health centers are designed to provide primary care to underserved populations.
Family Health Centers has sites in Lee, Charlotte and Hendry counties, its website shows.
Family Health Centers sues state over Medicaid reimbursement increase for expanded services
The legal dispute involves a complicated formula that the state uses to determine how much to reimburse federally qualified health centers for treating Medicaid beneficiaries. The ruling said federal law requires states to reimburse the centers on a per-patient basis for certain services.
Family Health Centers in 2019 requested a boost in its reimbursement rate, saying it had increased services in the region. Tuesday's ruling said the state rejected the "bulk" of the request, leading to Family Health Centers filing the federal lawsuit.
The dispute centered on part of a federal law that required states to raise reimbursement rates when federally qualified health centers have an increase in the "scope" of services.
"For instance, Family Health argues that, among other things, the 'range' or 'extent' — and thus the 'scope' — of an FQHC's services increases when it, say, cares for a sicker population of patients (who need more services and higher-level treatment), offers new 'treatment modalities' (e.g., a fluoride regimen added to routine teeth cleanings), purchases more advanced equipment or adds new service locations," said Tuesday's ruling shared by Judges Robin Rosenbaum, Kevin Newsom and Nancy Abudu.
But the state argued for a narrower interpretation of the "scope" of services, saying it applies to the addition or elimination of services, the ruling said.
Appeals court backs clinic's interpretation
The appeals court, in a 10-page main opinion, backed the Family Health Centers' interpretation and the district judge's order for the state to develop a new Medicaid plan.
"Although the issue is certainly not without complexity, we hold that the district court correctly ruled that the ordinary meaning of the phrase 'any increase... in the scope of such services' encompasses more than just the addition of a new service," the appeals-court panel said. "As the district court observed, the term 'scope' can mean the 'range' or 'extent' of something. As so defined, the phrase 'increase... in the scope of such services' might include any of a number of service expansions other than the addition of an entirely new service."
