Samissa Anchorage, Inc. v. Department of Health & Social Services

Summary

The Alaska Supreme Court held that a Medicaid provider challenging reimbursement rates under AS 47.07.070 through administrative procedures was not entitled to prejudgment interest. The court concluded that AS 09.50.250 and AS 09.50.280 did not waive the state's sovereign immunity for such administrative rate challenges because the provider could not maintain an independent contract action under those provisions. The court affirmed the superior court's decision denying prejudgment interest.

Holdings

1. AS 09.50.280 does not authorize prejudgment interest for Medicaid reimbursement rate challenges brought under AS 47.07.070 and the related administrative procedures in 7 AAC 43.703 and .704.
2. It is unnecessary to decide whether North Star had a contract with the department because its Medicaid rate dispute was required to proceed as an administrative challenge rather than as an independent contract, quasi-contract, or unjust-enrichment action under AS 09.50.250.
3. The legislature did not intend prejudgment interest to be a remedy for delay in Medicaid rate-making proceedings under AS 47.07.

Questions Presented

1. Whether AS 09.50.280 authorizes prejudgment interest against the State of Alaska for Medicaid reimbursement rate challenges brought through the administrative procedures governing AS 47.07.070.
2. Whether North Star's Medicaid provider agreement, contract or quasi-contract theories, exhaustion of administrative remedies, unjust-enrichment theory, or the alleged time value of withheld funds provided an alternative statutory basis for prejudgment interest.
3. Whether the administrative Medicaid rate challenges were claims encompassed by the State's waiver of sovereign immunity in AS 09.50.250.

Disposition

affirmed