{
  "id": 3049065,
  "name": "Michael Reese Hospital, Claimant, v. The State of Illinois, Respondent",
  "name_abbreviation": "Michael Reese Hospital v. State",
  "decision_date": "1992-03-24",
  "docket_number": "No. 84-CC-1890",
  "first_page": "61",
  "last_page": "65",
  "citations": [
    {
      "type": "official",
      "cite": "44 Ill. Ct. Cl. 61"
    }
  ],
  "court": {
    "name_abbreviation": "Ill. Ct. Cl.",
    "id": 8793,
    "name": "Illinois Court of Claims"
  },
  "jurisdiction": {
    "id": 29,
    "name_long": "Illinois",
    "name": "Ill."
  },
  "cites_to": [
    {
      "cite": "38 Ill. Ct. Cl. 204",
      "category": "reporters:state",
      "reporter": "Ill. Ct. Cl.",
      "case_ids": [
        3058413
      ],
      "opinion_index": 0,
      "case_paths": [
        "/ill-ct-cl/38/0204-01"
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    {
      "cite": "40 Ill. Ct. Cl. 273",
      "category": "reporters:state",
      "reporter": "Ill. Ct. Cl.",
      "weight": 2,
      "opinion_index": 0
    },
    {
      "cite": "42 C.F.R. \u00a7\u00a7435.732",
      "category": "laws:admin_compilation",
      "reporter": "C.F.R.",
      "opinion_index": 0
    },
    {
      "cite": "44 Ill. Ct. Cl. 431",
      "category": "reporters:state",
      "reporter": "Ill. Ct. Cl.",
      "opinion_index": 0
    }
  ],
  "analysis": {
    "cardinality": 376,
    "char_count": 6472,
    "ocr_confidence": 0.892,
    "pagerank": {
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    "word_count": 1011
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  "last_updated": "2023-07-14T20:39:29.978535+00:00",
  "provenance": {
    "date_added": "2019-08-29",
    "source": "Harvard",
    "batch": "2018"
  },
  "casebody": {
    "judges": [],
    "parties": [
      "Michael Reese Hospital, Claimant, v. The State of Illinois, Respondent."
    ],
    "opinions": [
      {
        "text": "OPINION\nSommer, J.\nThe Claimant hospital here seeks $4,457.12 from the Illinois Department of Public Aid (IDPA), pursuant to section 11\u201413 of the Public Aid Code (or \u201cPAC,\u201d Ill. Rev. Stat. 1981, ch. 23, par. 11\u201413), for two days of \u201ccovered\u201d inpatient care rendered during August 1982 to patient Turner, a Spenddown recipient of MANG (Medical Assistance-No Grant, per PAC section 5\u20142(2)) under IDPA\u2019s Medical Assistance Program (MAP). Respondent denies all payment liability for these medical services and contends that recipient Turner\u2019s own $1,164.00 monthly payment obligation, under IDPA\u2019s Spenddown policy, is greater in amount than the per-diem-rate total ($882.80) which otherwise would have been payable by IDPA in the absence of Turner\u2019s Spenddown obligation.\nClaimant\u2019s $441.40 inpatient per diem rate under its contract with IDPA \u2014 rather than its \u201cprivate pay\u201d rate\u2014 is the rate by which the dollar amount of liability for services rendered to IDPA recipients is determined (see section 5\u20145.11 of PAC 1983; and Franciscan Medical Center v. State (1991), 44 Ill. Ct. Cl. 431); and $441.40 was the payment rate which Claimant here properly utilized in calculating patient Turner\u2019s service charges. Thus, IDPA\u2019s contractual obligation to Claimant for these services, in the absence of Spenddown, would have been $882.80 (2 days care @ $441.40), not the $4,457.12 total of Claimant\u2019s private-pay charges.\nThe purpose of Spenddown is to ensure equitable consideration of certain \u201cmedically needy\u201d persons having income and assets at levels greater in amount than the levels established as the \u201cstandard\u201d for MAP eligibility as of right, but who may realistically be as indigent, because of the medical expenses which they incur, as other. MAP-eligible recipients having lesser income or assets. The Spenddown-program enrollee and his or her medical vendors are all required to take an active part in the process of determining the point in time at which the enrollee\u2019s medical debts equal or exceed his or her own Spenddown obligation.\nTo become an eligible \u201crecipient\u201d in respect to medical services rendered during a given calendar month within the Spenddown enrollment period, the enrollee must be adjudicated by IDPA\u2019s local office to have incurred sufficient expenses for services rendered during or prior to that month to \u201cmeet\u201d (equal or exceed) the enrollee\u2019s own Spenddown obligation or \u201camount.\u201d\n\u201cSuch action [is] to assure that the patient had paid or incurred sufficient medical-expense obligations * 0 \u2022 to bring his income level within the monthly Spenddown \u2018standard\u2019 which IDPA had established for him, pursuant to federal Medicaid regulations (42 C.F.R. \u00a7\u00a7435.732 and 435.831) and IDPA Rules 120.10, 120.20, 120.30 and 120.60 [89 Ill. Adm. Code \u00a7\u00a7120.10, 120.20, 120.30 & 120.60] \" \u2018 In effect, a Medicaid Spenddownenrollee \u00b0 \u00b0 \u00b0 must comply with Spenddown requirements, and thereby reestablish his MAP eligibility, on a month-by-month basis.\u201d (Franciscan Medical Center v. State (1988), 40 Ill. Ct. Cl. 273.)\nThe enrollee is ineligible for MAP benefits \u2022 during a given month, unless adjudicated by the local IDPA office to have \u201cmet\u201d his or her Spenddown amount for that month, and unless the enrollee\u2019s vendors submit their related charges to that office promptly so as to permit adjudication to occur within the one-year period prescribed by regulation (42 C.F.R. section 447.45(d) and IDPA rule 140.20). Topics 105 and 141.2 of IDPA\u2019s MAP Handbooks for medical vendors; and Mercy Hospital v. State (1985), 38 Ill. Ct. Cl. 204.\nOnce IDPA\u2019s local office determines that the enrollee\u2019s Spenddown obligation for a given month has been met, the enrollee becomes a recipient (i.e., MAP-eligible) as to all services rendered on and after his/her \u201cSpenddown Met\u201d date through the end of that month; and that office issues a Split Billing Transmittal (DPA form 2432) to each known vendor, reporting therein the dollar amount of the recipient\u2019s obligation to be listed as a credit or deduction on the vendor\u2019s invoice.\n\u201cThe Department is not responsible for payment of expenses incurred that are used by the spenddown [recipient] toward meeting the spenddown obligation.\u201d (Handbook topic 105)\nSuch expenses, as reported in the DPA 2432, are the recipient\u2019s responsibility to pay. The vendor\u2019s invoice to IDPA must be restricted to charges for services rendered on and after the recipient\u2019s Spenddown Met date (i.e., for the period when the enrollee qualified as a \u201crecipient\u201d); must list charges calculated at IDPA\u2019s payment rate,\n\u201cwith such charges reduced by the amount of the patient\u2019s Spenddown obligation pertaining to the charges dates of service.\u201d (Franciscan Medical Center v. State (1988), 40 Ill. Ct. Cl. 273.)\nand must be submitted to IDPA within the one-year period prescribed by IDPA rule 140.20 (89 Ill. Adm. Code section 140.20) and section 447.45(d) of 42 C.F.R., with a copy of the DPA 2432 attached to the invoice Handbook topic 105.\nIn this case, patient Turner was obliged to assume liability for paying, from her own funds, the initial $1,164.00 (her Spenddown amount) in medical expenses which she incurred during August 1982, as determined by IDPA\u2019s local office. Her Spenddown Met date, as established by that office, was August 11th, the date of her admission to Claimant\u2019s facility. As Turner had not incurred any medical expense during that month prior to August 11th, and as her Spenddown obligation exceeded Claimant\u2019s $882.80 charge, Turner was responsible for paying Claimant\u2019s entire charge, with IDPA being responsible for her subsequent medical expenses incurred during that month.\nRespondent has moved for summary judgment, pursuant to section 2\u20141005(b) of the Code of Civil Procedure (Ill. Rev. Stat., ch. 110, par. 2\u20141005(b)), asserting that Claimant\u2019s entire $882.80 charge is Turner\u2019s payment responsibility. Based upon the above discussion, the Court finds that Turner is solely liable for payment of these services, and therefore grants Respondent\u2019s motion.\nIt is therefore hereby ordered and adjudged that judgment as to all issues is entered against Claimant Michael Reese Hospital and in favor of Respondent, and this claim is dismissed.",
        "type": "majority",
        "author": "Sommer, J."
      }
    ],
    "attorneys": [
      "Lawrence Friedman Law Offices, for Claimant.",
      "Roland W. Burris, Attorney General (Steven Schmall, Assistant Attorney General, of counsel), for Respondent."
    ],
    "corrections": "",
    "head_matter": "(No. 84-CC-1890\nMichael Reese Hospital, Claimant, v. The State of Illinois, Respondent.\nOpinion filed Mach 24, 1992.\nLawrence Friedman Law Offices, for Claimant.\nRoland W. Burris, Attorney General (Steven Schmall, Assistant Attorney General, of counsel), for Respondent."
  },
  "file_name": "0061-01",
  "first_page_order": 169,
  "last_page_order": 173
}