The Rancho Los Amigos National Rehabilitation Center, a public hospital operated by the Los Angeles County government, was scheduled to close permanently on June 30, 2003. The hospital was a 207-bed facility specializing in the rehabilitation and acute care needs of patients with chronic diseases. Public services for the severely disabled had been consolidated at the site, and the facility provided a rare opportunity for people with multiple serious disabilities to receive full care in one location for their conditions. At the time, the hospital served more than 9500 patients per year in its inpatient and outpatient programs. Of these patients, about half were covered by Medi-Cal, California's Medicaid welfare program.
On March 6 of 2003, Plaintiffs filed a class action lawsuit in the United States District Court for the Central District of California, seeking to enjoin the County from closing the hospital. The case was brought under Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12131-12165, and the Social Security Act, U.S.C. 12 §§ 13961, 1396d. Class certification was granted on April 29, 2003. Although their complaint has not been obtained by the Clearinghouse, the Plaintiffs' claims can be reconstructed from the court's Order Granting the Plantiffs' Motion for Preliminary Injunction, issued May 6, 2003. The Plaintiffs argued that the if the hospital were to close, they and other disabled individuals similarly situated would be unable to have their medical needs met in Los Angeles County, which would be impermissible, because the Social Security Act requires participating states to ensure that inpatient and outpatient hospital services be available to persons entitled to Medicaid services, and also requires that medically necessary and appropriate services be received on a timely basis, and that access to such services be comparable to that available to persons in the community who have private health coverage.
The court, in granting the order for a preliminary injunction, found that the Plaintiffs' case was likely to succeed on its merits. The County argued that closing the hospital would be fiscally responsible, saving the County $58.6 million a year. The court found the County's reasoning to be fallacious, because it did not account for the added cost of treating the hospital's patients at other facilities in the County. The court reasoned that the cost to the County would be greater if the hospital were to close than if it remained open. The court also determined that closing the hospital without first ensuring that comparable services would be available to its disabled Medi-Cal patients elsewhere in the County would be illegal under the ADA, because in doing so the County would be distributing public benefits and services in a manner that discriminated against the disabled.
The court's preliminary injunction was thus granted, to remain in force until the case reached a final judgment, or until the court issued revised order. The County filed an appeal on the May 8, 2003. On February 5, 2004, the Ninth Circuit Court of Appeals (Pregerson, J.) issued an opinion upholding the preliminary injunction, and holding that the plaintiffs "had demonstrated that if the County close[d] Rancho, it [would] reduce, and in some instances eliminate, necessary medical services for disabled Medi-Cal patients while continuing to provide the medical care required and sought by Medi-Cal recipients without disabilities" and that this disparity in providing services constituted discrimination under the ADA. Rodde v. Bonta, 357 F.3d 988 (M.D. Cal 2004).
The parties reached a settlement, which received preliminary approval on October 3, 2005 and final approval on January 30, 2006. In the settlement, the County agreed that Rancho Los Amigos National Rehabilitation Center would remain open for at least another three years, maintaining at least the same level of service as was available in March 2003. In the settlement, the County expressed its intent to find a purchaser or partner to take over the operation of the hospital. The plaintiffs retained their right to bring legal action against any future efforts to either close or reduce the level of services available to Medi-Cal patients at the facility. In accordance with this settlement, on January 30, 2006, the court ordered the County of Los Angeles to pay $1.75 million in legal fees to the Western Center for Disability Rights.
At the time of this writing, June 2013, Rancho Los Amigos National Rehabilitation Center is still in operation and appears to still be operated by the Los Angeles County Department of Health Services.
Although this case does not rely on or cite the Supreme Court's decision in Olmstead v. L.C., 527 U.S. 581 (1999), which held that the ADA forbids the unnecessary institutionalization of disabled individuals, the Clearinghouse includes it in our collection of Olmstead cases because it stands for a correlative principle, that disabled Medicaid recipients must be provided access to levels of care sufficient to allow them to live as independent and integrated members of the community.
Alex Colbert-Taylor - 06/03/2013
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