Palmdale Hospital Medical Center v. Department of Health Services

The California Department of Health Services (Department) appeals from a judgment granting a peremptory writ of mandate. The writ prohibits the Department from altering its final Medi-Cal settlements with plaintiffs Palmdale Hospital Medical Center and Vista Hill Hospital because the Department’s adjustments were made more than three years after the hospitals submitted cost reports. We reach the merits of the case after deciding that the Department is not collaterally estopped from challenging this ruling by a previous adjudication against the Department, on the same issue but in another action involving a different health care facility. On the merits, we conclude that the three-year period in Welfare and Institutions Code section 14170 applies only to the Department’s audit or review of the cost report of a Medi-Cal provider, and is not a general statute of limitations applicable to the final determination of the amount of reimbursement due to the provider. For this reason, the Department was not precluded from adjusting the amount of reimbursement due to the hospitals after the three-year period had expired. We therefore reverse the judgment.

Factual and Procedural…