TUMMALA RAMABRAHMAM, Claimant, v. THE STATE OF ILLINOIS, Respondent.
Case summary
Claimant sought payment for medical services rendered to a public aid recipient. The court dismissed the claim because the action was filed more than one year after the remittance advice notice of refusal and because the claimant failed to submit a corrected rebill invoice within the required one-year period.
Statutes cited: Ill. Rev. Stat., ch. 23, par. 11-13
Cases cited: Methodist Medical Center v. State (1986), 38 Ill. Ct. Cl. 208; Memorial Medical Center v. State (1988), 40 Ill. Ct. Cl. 73, 77-78; Franciscan Medical Center v. State, No. 86-CC-0368; Riverside Medical Center v. State, No. 87-CC-0780; St. John's Hospital v. State, No. 86-CC-2055
AI-generated summary from the opinion text — may contain errors. The opinion text and PDF above are the official record.
Headnotes
- NEIL F. H ARTIGAN, Attorney General (STEVEN SCHMALL, Assistant Attorney General, of counsel), for Respondent.
- CoNmacrs-claim for services rendered welfare recipients-claim dismissed-failure to subnit timely corrected invoice. The Court of Claims dismissed a claim for medical services rendered to welfare recipients where the vendor failed to submit a corrected, rebill-invoice of the service within the prescribed one-year period.
- ’OPINION AND JUDGMENT
This is a vendor-payment action, filed pursuant to section 11-13 of the Public Aid Code (or “PAC,” Ill.
Rev. Stat., ch. 23, par. 11-13), in which Claimant is seeking payment from the Illinois Department of Public Aid (IDPA) of his charge for medical care rendered to a hospitalized patient and recipient of public aid. Claimant’s action was filed with this Court more than one year after the subject services had been rendered, and more than one year after IDPA had mailed to Claimant a remittance-advice, or “voucher” notice that it was “refusing to pay” (section 11-13 of the PAC) his initiallyinvoiced charge for said services. Respondent has moved for summary judgment, citing Claimant’s failure to commence this action within the time prescribed by statute, as well as his failure to submit a properly corrected, rebill-invoice of said charge to IDPA, with his services properly identified by appropriate procedure code, within the one-year period prescribed by IDPA [*352] Rule 140.20 (89 Ill. Admin. Code 140.20) and by Federal Medicaid regulation (42 C.F.R. 9447.45(d)).
IDPA sent Claimant a “remittance advice” notice of its refusal to pay his invoice, which notice listed “invalid procedure code” as its reason for such refusal; and that Claimant thereafter failed to submit a corrected, rebillinvoice of said service to IDPA, within the one-year period prescribed by IDPA Rule 140.20 and 42 C.F.R., section 447.45(d). A vendor must comply timely with each of the aforementioned requirements, as each is a condition precedent to an award by this Court.
Methodist Medical Center u. State (1986), 38 Ill. Ct. C1. 208; Memoriul Medical Center u. State (1988),40 Ill. Ct.
Cl. 73, 77-78, and decisions therein cited; Franciscan Medical Center u. State, No. 86-CC-0368; Riverside Medical Center u. State, No. 87-CC-0780; and St. John’s Hospital v . State, No. 86-CC-2055.
In its report, IDPA advises that the hospital in which said surgery was performed, and two other physicians who treated this patient during his hospitalization, had all invoiced their services-properly identified-in the manner and within the time prescribed by the Handbook and IDPA Rule requirements; and that each such vendor had been paid by IDPA for such services.
It is therefore hereby ordered and adjudged that Respondent’s motion for summary judgment is granted, and this claim is dismissed with prejudice.