In re The Estate of Michael Patrick Smith v. Heckler

The Estate of Michael Patrick Smith (the Estate) (plaintiff) brought a class action suit against Heckler, the Secretary of the U.S. Department of Health and Human Services (HHS) (defendant). The suit was brought on behalf of Medicaid recipients residing in Colorado nursing homes. The Estate alleged that Heckler had a statutory duty under the Medicaid Act to develop and implement a compliance review and enforcement mechanism to ensure that residents in Medicaid-certified nursing homes received quality health care. The Estate argued that Heckler did not meet the statutory mandate because the enforcement system was “facility-oriented,” instead of “patient-oriented.” The Medicaid Act gives the HHS Secretary the authority to make an independent determination of whether the facility is compliant separate from any state determination. The Estate argued that the Heckler’s method of review evaluated only the physical facilities providing the care and did not adequately determine the quality of care delivered to residents. The district court held that Hecker’s decision not to use a “patient-oriented” system was not a violation of the Secretary’s statutory duty and found that the State of Colorado would have been the proper defendant because it was responsible for developing and enforcing standards to ensure quality resident care. The Estate appealed the district court’s decision.