Argument of Speaker
Mr. Speaker: Justice Steven says the opinion in 04-1506, Arkansas Department of Health and Human Services versus Ahlborn.
Argument of Justice Stevens
Mr. Stevens: This case comes to us on writ of certiorari to the Court of Appeals for the 8th Circuit.
We granted review to decide whether a State can, consistent with federal Medicaid law, assert a lien on a Medicaid recipient’s tort settlement in an amount exceeding the portion of the settlement that represents payments for medical care.
Heidi Ahlborn was severely injured in a car accident in 1996.
Because she was unable to pay all of her medical costs, Arkansas, through its federally subsidized Medicaid program, paid roughly $215,000.00 of medical expenses on her behalf.
Meanwhile, Ahlborn sued the individuals allegedly responsible for her injuries.
Arkansas intervened in that suit to assert a lien on any settlement, but did not actually participate in settlement negotiations that ultimately took place.
She received an unallocated settlement in the amount of $550,000.00.
Although Arkansas stipulated that only about $35,000.00 of that settlement represented payments for medical care, it nonetheless asserts that it’s entitled to full reimbursement in the amount of about $215,000.00 for all costs it paid on Ahlborn’s behalf under the Medicaid system.
In an opinion filed with the Clerk of the Court today, we affirm the 8th Circuit’s ruling that Arkansas is entitled only to the portion of Ahlborn’s settlement that represents payments for medical care, that is, $35,000.00.
Under the federal Medicaid provisions, a State can -- indeed, it must -- require a Medicaid recipient to assign her rights to recovery from third parties of, quote, “payments for medical care,” unquote; but the federal statute neither requires nor authorizes assignment of rights to payment for other items of damage and, in fact, the federal and anti-lien statute affirmatively prohibits Arkansas’s placement of a lien on property of the recipient that does not constitute third-party payments for medical care.
Such property includes the part of Ahlborn’s settlement that represents nonmedical damages.
To the extent Arkansas statutorily inviolates the federal anti-lien provision, it cannot be enforced.
Our opinion is unanimous.
