Appalachian Regional Healthcare, Inc. v. West Virginia Department of Health & Human Resources

Summary

The Supreme Court of Appeals of West Virginia affirmed dismissal under Rule 12(b)(6) of Appalachian Regional Healthcare’s claims challenging Medicaid reimbursement rates. The court held that West Virginia Code §§ 9-15-16 and 16-29B-20 provide neither an express nor an implied private cause of action for a Medicaid provider to obtain judicial review of reimbursement rates. The opinion also addressed the statutory allocation of Medicaid rate-setting authority and related federal Medicaid requirements.

Holdings

1. West Virginia Code § 9-5-16 does not provide an express or implied private cause of action by a Medicaid provider for judicial review of reimbursement rates for medical services.
2. West Virginia Code § 16-29B-20 does not provide an express or implied private cause of action by a Medicaid provider to challenge Medicaid reimbursement rates.
3. Dismissal was proper because none of the complaint's ten counts stated a legally cognizable claim for relief based on the statutes relied upon or the asserted alternative theories.

Questions Presented

1. Whether West Virginia Code § 9-5-16 provides an express or implied private cause of action allowing a Medicaid provider to obtain judicial review of Medicaid reimbursement rates.
2. Whether West Virginia Code § 16-29B-20 provides an express or implied private cause of action allowing a Medicaid provider to challenge Medicaid reimbursement rates.
3. Whether the complaint stated any viable claim for relief based on the asserted statutory, constitutional, contract, quantum meruit, or related theories.

Disposition

affirmed