Introduction

In the case titled Petition of Jacob Solomon Mason & others (2024 N.H. 67), the Supreme Court of New Hampshire addressed pivotal issues concerning the termination of state funding for developmental services and the adherence to federal regulations governing such services. The petitioners, comprising five individuals with severe developmental disabilities and their guardians, challenged the decision of the New Hampshire Department of Health and Human Services (DHHS) to cease funding their services at the Judge Rotenberg Educational Center, Inc. (JRC). The core disputes centered on whether the DHHS misapplied state and federal laws in terminating funding and denying the petitioners' right to an administrative appeal.

Summary of the Judgment

The New Hampshire Supreme Court affirmed the decision of the Commissioner of DHHS to grant summary judgment in favor of the Department's Bureau of Developmental Services (BDS). The court concluded that RSA Chapter 171-A explicitly prohibits BDS from utilizing state funds to pay for services provided by entities that do not comply with the federal Settings Rule. Consequently, the termination of funding to JRC, deemed non-compliant by the Centers for Medicare and Medicaid Services (CMS), was lawful. The court also recognized that the petitioners had a right to appeal the termination of services; however, the statutory restrictions superseded their arguments for continued funding.

Analysis

Precedents Cited

The judgment references several key cases and statutes that influenced the court’s decision. Notably:

• Krainewood Shores Association v. Town of Moultonborough, 174 N.H. 103 (2021) – Utilized for interpreting the phrase “in accordance with.”
• PETITION OF STRANDELL, 132 N.H. 110 (1989) – Affirmed that administrative officials must adhere strictly to statutory mandates.
• Petition of Guillemette, 171 N.H. 565 (2018) – Established the framework for reviewing AAU decisions via writ of certiorari.
• Doe v. Commissioner, NH Department of Health & Human Servs., 174 N.H. 239 (2021) – Highlighted legislative authority to amend statutory schemes.

Legal Reasoning

The court meticulously dissected the statutory language of RSA Chapter 171-A, particularly sections 171-A:2, I-b and 171-A:18, II, which mandate compliance with the federal Settings Rule (42 C.F.R. § 441.301). By interpreting the phrase “in accordance with” as requiring harmony and conformity with federal standards, the court upheld that DHHS could not allocate state funds to non-compliant providers like JRC. The court emphasized that administrative agencies cannot contravene explicit statutory directives, thus reinforcing the supremacy of legislative language over administrative discretion.

Furthermore, the court applied principles of statutory construction, focusing on the plain and ordinary meaning of the language, legislative intent, and the overall purpose of the statutes. By doing so, it determined that DHHS's termination of funding was legally justified under the existing statutory framework.

Impact

This judgment solidifies the necessity for state agencies to adhere strictly to both state and federal regulations when administering funding for developmental services. Future cases involving the termination of services or appeals regarding funding decisions will likely reference this precedent to ensure compliance with established statutory mandates. Additionally, providers offering developmental services must align their operations with federal standards to qualify for state funding, thereby potentially increasing oversight and standardization within the sector.

Complex Concepts Simplified

Settings Rule

The Settings Rule is a federal regulation (42 C.F.R. § 441.301) established by the Centers for Medicare and Medicaid Services (CMS) to ensure that home and community-based services (HCBS) are provided in environments that support the well-being and integration of individuals with disabilities. It sets specific standards for the care settings, including staffing, safety, and service delivery protocols.

HCBS Waiver Funding

HCBS Waiver Funding refers to federal funds provided under Section 1915(c) of the Social Security Act, allowing states to finance community-based services for individuals with disabilities. This funding enables services that help individuals live in less restrictive environments rather than institutional settings.

RSA Chapter 171-A

RSA Chapter 171-A is a New Hampshire statute governing the provision of services to individuals with developmental disabilities. It outlines the responsibilities of the Department of Health and Human Services (DHHS), establishes rules for service providers, and ensures that services meet both state and federal standards.

Conclusion

The Supreme Court of New Hampshire's decision in Petition of Jacob Solomon Mason & others reinforces the imperative for state-funded developmental services to comply rigorously with federal regulations. By affirming that RSA Chapter 171-A prohibits the use of state funds for non-compliant providers, the court ensures the integrity and quality of services provided to vulnerable populations. This ruling not only delineates the boundaries of administrative discretion but also safeguards the rights of individuals with developmental disabilities to receive services that meet established standards.

The judgment serves as a critical reminder to state agencies and service providers about the paramount importance of adhering to statutory and regulatory frameworks. It underscores the judiciary's role in upholding legislative intent and ensuring that administrative actions align with the law, thereby fostering accountability and protecting the interests of those reliant on state-funded services.