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Bioethics Keyed to Clark, 9th Ed.
Linton v. Commissioner of Health and Environment
Citation:
779 F. Supp. 925 (1990)Facts
The Tennessee Department of Health and Environment (TDHE) administered the state’s Medicaid program, which covered both skilled nursing and intermediate care facilities. Under Tennessee’s “limited bed certification” policy, nursing homes could designate which beds would be certified for Medicaid patients, often resulting in only a portion of beds being available to Medicaid recipients. This policy differed significantly from federal “distinct part” certification, which was designed to accommodate different types of care within the same facility, not to allow facilities to limit Medicaid access.
The policy led to displacement of patients who exhausted their private resources and transitioned to Medicaid, as well as patients who were downgraded from skilled to intermediate care. It also created barriers to nursing home access for new Medicaid patients. Statistical evidence showed that while Black individuals comprised 39.4% of Tennessee’s Medicaid population, they accounted for only 15.4% of Medicaid nursing home residents, demonstrating a disparate impact on minorities.
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