St. Alexius Medical Center, d/b/a Great Plains Rehabilitation v. North Dakota Department of Human Services

Summary

The North Dakota Supreme Court affirmed a district court judgment upholding the Department of Human Services’ determination that St. Alexius Medical Center, doing business as Great Plains Rehabilitation, received Medicaid overpayments subject to recoupment. The court held that the statutory seventy-five-day deadline for the Department’s final decision was directory rather than jurisdictional and had been waived by failure to raise it below. The court also held that the provider received the informal review process required by the specific Medicaid statute, adequate notice, and findings supported by the evidence.

Holdings

1. The seventy-five-day deadline in N.D.C.C. § 50-24.1-24(5) is directory rather than mandatory; the Department's failure to meet it does not terminate subject matter jurisdiction. Because the issue was not raised before the district court, it was waived.
2. The specific review procedure in N.D.C.C. § 50-24.1-24 governs provider appeals and prevails over the general adjudicative procedures of the Administrative Agencies Practice Act. The statute permits an informal paper-based agency review and does not require a traditional hearing, cross-examination, or rebuttal proceeding.
3. The Department's findings that Great Plains failed to properly document the diagnosis, medical necessity, and projected length of need were supported by the evidence.
4. Great Plains received adequate notice of the issues underlying the overpayment determinations and did not establish that the Department denied it a fair hearing.

Questions Presented

1. Whether the Department's failure to issue a final decision within the seventy-five-day period in N.D.C.C. § 50-24.1-24(5) deprived it of subject matter jurisdiction.
2. Whether the Department's informal review process violated the Administrative Agencies Practice Act or required a trial-like administrative hearing.
3. Whether the Department's findings that Great Plains failed to satisfy Medicaid documentation requirements were supported by the evidence.
4. Whether Great Plains received adequate notice and a fair hearing when the Department upheld the overpayment determination.

Disposition

affirmed