E.D.B. ex rel. D.B. v. Clair

Summary

The Pennsylvania Supreme Court held that the Department of Public Welfare could obtain reimbursement from a tortfeasor for Medicaid expenditures made on behalf of a disabled minor, even when the minor’s parents’ claim for the minor’s medical expenses was barred by the statute of limitations. The court concluded that the minor was a primary beneficiary under the Fraud and Abuse Control Act and that the Act conferred a statutory right to reimbursement from the settlement. The court vacated the Superior Court’s order and reinstated the common pleas court’s order approving reimbursement.

Holdings

1. Under the Fraud and Abuse Control Act, both a Medicaid recipient minor and the minor's parents acting as guardians are beneficiaries, with the minor being the primary beneficiary.
2. A Medicaid beneficiary has a cause of action against the tortfeasor to recover and reimburse DPW for Medicaid benefits received during the beneficiary's minority, and DPW may enforce its statutory lien against the beneficiary's settlement notwithstanding the parents' time-barred claim.
3. Arkansas Department of Health and Human Services v. Ahlborn limits the portion of a settlement from which a Medicaid lien may be satisfied, but it does not determine whether a minor is a beneficiary or whether Pennsylvania law permits DPW to recover Medicaid expenditures incurred during minority.

Questions Presented

1. Whether a minor child whose estate may be legally liable for medical expenses resulting from an injury can sue the tortfeasor for reimbursement of those expenses.
2. Whether the Pennsylvania Legislature intended the Fraud and Abuse Control Act to permit a minor receiving medical assistance to recover medical expenses from a tortfeasor.
3. Whether a minor child is a beneficiary under 62 P.S. § 1409(b)(13) for purposes of DPW's reimbursement lien.
4. Whether DPW may recover Medicaid expenditures made on behalf of a disabled minor when the parents' claim for those expenses is barred by the statute of limitations.

Disposition

vacated