Estelle Seittelman, as Administratrix of the Estate of Ida Zichlinsky, Deceased

Summary

The New York Court of Appeals held that New York's regulation limiting retroactive Medicaid reimbursement to services rendered by Medicaid-enrolled providers is irrational and contrary to federal law, rendering that limitation unenforceable. The Court also held that reimbursement may be made only at the Medicaid rate in effect when the services were provided, not for out-of-pocket expenses. The decision vacated part of the Supreme Court's order on the timing of reimbursement and remanded for further proceedings.