AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• A young man with spina bifida applied for admission to Princeton Place, a Medicaid-certified nursing facility. Under federal and New Mexico regulations, such facilities must implement a preadmission screening and annual resident review program (PASARR) to identify applicants with mental illness or intellectual disability. The New Mexico Human Services Department (HSD) initiated a recoupment action against Princeton for failing to forward the applicant's Level I screening for a Level II screening, alleging non-compliance with PASARR regulations during the applicant's stay (paras 1-2, 10-12).

Procedural History

• District Court: Upheld the agency recoupment action against Princeton.
• Court of Appeals: Reversed the district court's decision, holding that the Department of Health (DOH) PASARR Level I screening form is unenforceable because it was not promulgated pursuant to the State Rules Act, and that an applicant must have an indication of mental illness in addition to a developmental disability to be suspected of having a “related condition” (para 2).

Parties' Submissions

• Respondent-Petitioner (HSD): Argued that the Court of Appeals erred in holding the DOH PASARR Level I screening form unenforceable and in requiring an indication of mental illness in addition to a developmental disability for a “related condition” (para 2).
• Petitioner-Respondent (Princeton): Defended its decision not to initiate a Level II screening based on the applicant's spina bifida diagnosis, asserting that the applicant did not show signs of intellectual disability or a related condition requiring further evaluation (paras 10-11, 14).
• Amici Curiae (New Mexico Health Care Association and New Mexico Center for Assisted Living): Supported Princeton's position, arguing against the enforcement action based on the unenforceability of the DOH PASARR form and instructions (para 17).

Legal Issues

• Whether the DOH PASARR Level I screening form and instructions are enforceable despite not being promulgated pursuant to the State Rules Act (para 3).
• Whether an applicant must have an indication of mental illness in addition to a developmental disability to be suspected of having a “related condition” under 42 C.F.R. § 435.1010 (para 2).

Disposition

• The Supreme Court of the State of New Mexico reversed the Court of Appeals, holding that the DOH PASARR Level I screening form and instructions are interpretive agency guidance not requiring promulgation pursuant to the State Rules Act, and that the HSD interpretation of “related condition” to include spina bifida, thus requiring a Level II screening in this case, is not arbitrary and capricious, is supported by substantial evidence, and is otherwise consistent with the law (para 3).

Reasons

• The Supreme Court found that the argument regarding the enforceability of the DOH form was not preserved for appellate review but decided the issue on the merits due to general public interest. The Court held that the screening form and instructions are interpretive agency guidance, not requiring promulgation under the State Rules Act, and do not carry the full force of law. The Court also held that the HSD interpretation of “related condition” under 42 C.F.R. § 435.1010 to include spina bifida was reasonable, supported by substantial evidence, and in accordance with the law. The Court concluded that Princeton did not have discretion to decide against initiating a Level II screening based on its determination that the applicant did not meet the definition of a person with a related condition, as this determination is the sole province of the state mental health and intellectual disability authority (paras 20-42).