Fourth Department — Medicaid: County of Niagara v. Daines

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Appellate Division, Fourth Department

Medicaid

Overburden Expenditures — Reimbursement

County of Niagara v. Daines
CA 11-01219
Appealed from Supreme Court, Niagara County

Background: The petitioner, a county that is also a social services district, commenced an Article 78 proceeding seeking to annul the denial of its claim for reimbursement for Medicaid expenditures known as “overburden expenditures.” The respondents appealed from the judgment that granted the petition seeking reimbursement for pre-2006 overburden expenditures. The respondent argued that the court had erred because a 2010 amendment to the law known as the Medicaid Cap Statute extinguished the petitioner’s right to reimbursement.

Ruling: The Appellate Division unanimously affirmed. The Appellate Division held that the respondents’ duty to reimburse social services districts for overburden expenditures incurred prior to 2006 was not extinguished by the original Medicaid Cap Statute. This duty could only be extinguished by amendment to the statute. The 2010 amendment’s plain language did not address overburden expenditures or respondents’ duty to pay them.

Victor Paladino of the New York State Office of the Attorney General for the respondents-appellants; Christopher E. Buckey of Whitemen Osterman & Hanna LLP for the petitioner-respondent