Nasello v. Eagleson

Federal 7th Circuit Court
Civil Court
Medicaid
Citation
Case Number: 
No. 19-3215
Decision Date: 
October 6, 2020
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed

Dist. Ct. did not err in dismissing plaintiffs' action alleging that defendants improperly failed to treat plaintiffs' past or outstanding medical bills as equivalent to their current medical outlays for purposes of determining their Medicaid benefits as “medically needy” individuals. While plaintiffs premised claim on language contained in 42 USC section 1386a(r)(1)(A), said statute did not create private cause of action to enforce provisions of said section. Also, plaintiffs could not proceed under 42 USC section 1396a(a)(8), where plaintiffs’ grievance was not about timing of benefits, but rather about amount of benefits. Moreover, fact that instant benefits are not as high as plaintiffs would want is not form of discrimination under Americans with Disabilities Act (ADA), where: (1) plaintiffs have not identified any accommodation that would be required by ADA that would also comport with terms of Medicaid Act; and (2) plaintiffs have not been penalized because of administrative hurdles that bear more heavily on disabled individuals.