Presbyterian Medical Center of Oakmont v. Department of Public Welfare

Nursing center suffered no unconstitutional "forfeiture" where state rejected Medical Assistance invoices as untimely under reasonable and generous regulatory deadline.

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Argued: December 3, 2001

Presbyterian Medical Center of Oakmont (PMC), an enrolled provider of nursing facility services in the Commonwealth’s Medical Assistance (MA) Program, petitions this Court to review the final orders of the Director of the Bureau of Hearings and Appeals of the Department of Public Welfare (DPW) that affirmed a decision of DPW to deny compensation for services provided to twenty recipients because of Presbyterian’s late or incorrectly submitted invoices for such services. We affirm.

DPW’s regulations, set forth at 55 Pa. Code �1101.68, govern the time and manner by which MA nursing facility providers must submit to DPW their claims for payment for services provided to MA recipients.*fn1 Under Section 1101.68, an MA provider must submit an original invoice within 180 days of the date the provider renders services to an eligible MA recipient. If the provider fails to submit the invoice within the mandatory 180-day time frame, DPW is required to reject the invoice unless the provider meets the requirements for an exception to the 180-day rule as set forth at Section 1101.68(c) and (d).

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Presbyterian Medical Center of Oakmont v. Department of Public Welfare

Nursing center suffered no unconstitutional "forfeiture" where state rejected Medical Assistance invoices as untimely under reasonable and generous regulatory deadline.

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