44 N.Y.2d 909 (1978)
A nursing home, as a service provider under Medicaid, does not have standing to challenge a patient’s Medicaid ineligibility determination when the patient fails to do so.
Summary
Peninsula General Nursing Home sought a hearing to challenge the denial of Medicaid benefits to a patient who had received services at the facility. The New York Court of Appeals reversed the Appellate Division’s decision, holding that the nursing home lacked standing to challenge the Medicaid ineligibility determination because the patient, the primary party in interest, had not challenged the determination. The dissent argued that denying the provider a hearing was irrational and undermined the purpose of the Medicaid program, potentially forcing providers to either sue indigent patients or withdraw from the program.
Facts
Peninsula General Nursing Home provided services to a patient. The Department of Social Services determined that the patient was ineligible for Medicaid benefits. The patient did not challenge this determination. The nursing home, seeking payment for the services rendered, attempted to challenge the ineligibility determination on its own behalf.
Procedural History
The case reached the New York Court of Appeals after a decision by the Appellate Division. The Court of Appeals reversed, adopting the dissenting opinion from the Appellate Division, which argued against granting standing to the nursing home.
Issue(s)
Whether a nursing home, as a Medicaid service provider, has standing to challenge a Medicaid ineligibility determination made regarding one of its patients when the patient has not challenged that determination.
Holding
No, because the nursing home lacks standing to challenge the determination when the patient does not pursue their right to a hearing.
Court’s Reasoning
The Court of Appeals adopted the dissenting opinion from the Appellate Division. The dissent argued that the provider’s recourse was a plenary suit against the patient, although recognizing the impracticality of this approach. The dissent in the Court of Appeals argued that precluding the provider from a hearing was irrational and contrary to the legislative intent of Medicaid. The dissenting opinion stated, “It seems totally irrational to preclude the provider, the real party in interest, from obtaining a fair hearing on the issue of whether the patient who is receiving care is eligible for medical benefits.” The dissent also pointed out the absurdity of forcing an indigent patient to defend a lawsuit to recover charges they are too poor to pay. The dissent further warned that such a decision could lead providers to withdraw from the Medicaid program, undermining its purpose.