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University of Chicago Hospital v. State of Illinois

36 Ill. Ct. Cl. 296 Illinois Court of Claims Filed 1984-05-17 No. 83-CC-1590
Disposition: (No. 83-CC-1590-Claim dismissed.) Agency: Illinois Department of Public Aid
Cite as: University of Chicago Hospital v. State of Illinois, 36 Ill. Ct. Cl. 296 (1984)
General Court of Claims 36 dismissed 1980s University of Chicago Hospital v. State of Illinois 36 Ill. Ct. Cl. 296 1984-05-17 (No. 83-CC-1590-Claim dismissed.) /opinions/v36-p0381-1/

UNIVERSITY OF CHICAGO HOSPITAL, Claimant, v. THE STATE OF ILLINOIS, Respondent. i '

Case summary

The hospital sought payment for neonatal services provided to a newborn whose mother was a public aid recipient, but no application for recipient status was made for the infant. The court dismissed the claim because the infant was not eligible for state-paid medical assistance.

Claim type: Other

Statutes cited: Ill. Rev. Stat. 1983, ch. 23, par. 11-13; Ill. Rev. Stat. 1983, ch. 23, par. 11-15

AI-generated summary from the opinion text — may contain errors. The opinion text and PDF above are the official record.

Headnotes

  1. PUBLIC AID Com-neonatal care-ineligible child-cluim denied. Hospital's claim for neonatal services rendered for newborn child of. public aid recipient was denied, as services were rendered after mother.was discharged from hospital and no application was ever made to make child eligible for medical assistance program in its own right, and'a newborn child does not become a recipient simply as a result of birth to a recipient mother, since all persons wishing benefits-must timely apply. , . , ,

This cause coming on to be heard on Respondent's motion to dismiss, due notice having been given and the. Court being.fully advised finds as follows: . . '

The University of Chicago Hospital is here seeking a $2,793:60,vendorpayment, as provided in,section 11-13 of the Public Aid Code (Ill. rev.

Stat. 1983, ch. 23, par. 11-13), from the Illinois Department .of Public Aid (IDPA), for inpatient neonatal services which it rendered to a newborn infant during May and June of 1979. The subject,services began with the date on.which the infant's . mother; a public aid recipient, was .discharged from [*297] Claimant’s hospital, and ended with the infant’s discharge eight days later.

As explained by IDPA in its departmental report, hospitals are to bill both the mother’s and the newborn’s care to IDPA on a single invoice, covering services from the mother’s admission for childbirth and including the days during which both mother and newborn were patients. Claimant did so in this case, and was paid in full by IDPA for*the services furnished-prior to the mother’s discharge. The subsequent neonatal services for this infant are not, however, eligible for payment by the State, since at no time here relevant did the mother apply to IDPA to request recipient status for her newborn daughter. In the absence of such application, IDPA had no authority to determine the infant’s eligibility for Statepaid medical assistance.

As IDPA points out, a newborn child does not become a recipient simply as a result of his or her birth to a recipient mother. All persons wishing the benefits of recipient status must timely apply to IDPA for that status. In the case of minor children, the Public Aid Code (Ill. Rev. Stat. 1983, ch. 23, par. 11-15) provides that a parent, relative or guardian may apply for recipient status on the minor’s behalf. IDPA’s medical assistance program (MAP) Handbook for Hospitals outlines the procedures whereby the Claimant could have aided the mother in applying for MAP coverage for her infant. Since no application was submitted, there was no MAP coverage for the subject services.

Because this infant was not determined eligible for recipient statusi with respect to the period during which these services were rendered, payment by the State would be contrary to IDPA requirements.

[*298] I

298 I

It is hereby ordered that the claim be dismissed, the ,

I

Claimant having failed to demonstrate an entitlement to I payment for the subject neonatal services.

Official volume 36 (Containing cases in which opinions were filed and orders of dismissal entered, without opinion for: Fiscal Year 1984 – July 1, 1983–June 30, 1984)  ·  All opinions in this volume  ·  Also on CourtListener

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