United Cerebral Palsy Of Georgia, Inc. Et Al.v.Georgia Department Of Behavioral Health And Developmental Disabilities Et Al.
Several Georgia providers serving people with developmental disabilities challenged Medicaid reimbursement decisions involving the state’s waiver programs. The Department of Community Health’s commissioner issued a final administrative decision, and the superior court affirmed it while dismissing the providers’ related putative class action for failure to exhaust administrative remedies. The Georgia Court of Appeals held that the superior court affirmed the agency decision on grounds that had not been presented in the motions for summary determination and that the agency, rather than the court, should address the complex reimbursement questions in the first instance. The court therefore vacated the affirmance and remanded with instructions to vacate the commissioner’s decision and remand to the agency for further action. It affirmed dismissal of the putative class action because the representative providers had not completed the administrative process. The decision reinforces agency expertise and exhaustion requirements while limiting judicial review to grounds properly raised below.
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