In Woodruff v. Indiana Family and Social Services, the Indiana Supreme Court ruled that a state Medicaid agency is not required to pay a provider's costs of care after certification needed to provide that care was terminated.
In the facts of the case, a provider established as an ICF/MR was decertified for Medicaid reimbursement due to not adequately meeting the minimum standards for a care facility. The provider continued to provide services despite the decertification and was denied expense reimbursement for the period of time after being decertified and prior to the state appointing a receiver nine months later.
The provider was advised that payments would be discontinued 30 days after decertification, or 120 days following an appeal, and that any payments beyond that period would be contingent upon transferring its residents to another certified ICF/MR. The provider did not transfer its residents and a subsequent filing requesting recertification was denied.
The court ruled that the provider should not have had an expectation of reimbursement following decertification and, therefore, was not entitled to the expenses.