Cospito v. Heckler
742 F.2d 72 (3rd Cir. 1984)
Nature Of The Case
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Facts
Trenton Psychiatric Hospital (TPH) is a state facility operated as a component of the Division of Mental Health and Hospitals, New Jersey State Department of Human Services. It treats both voluntarily and involuntarily committed patients for mental disease. TPH was surveyed under the standards for 'psychiatric facilities' recently promulgated under the auspices of JCAH. Major deficiencies were disclosed inpatient treatment, staffing, environment, and fire safety. TPH was accredited for only one year, and was notified that these deficiencies must be corrected to maintain accreditation. Next year many of the same deficiencies were found again. A preliminary decision was made by JCAH not to accredit. At TPH's request, a resurvey was conducted the following year which again resulted in a preliminary decision not to accredit. TPH did not appeal that decision, and the de-accreditation became final. In 1976, the Children's Unit had met the requisite standards and therefore was retroactively restored its accreditation. TPH also sought reaccreditation of the Adult Unit of the hospital in 1977 and 1979, but both times JCAH determined that accreditation should not be granted. Finally, in 1981, following another survey by JCAH, the Adult Unit regained its accreditation, and continues to operate under that approval today. JCAH accreditation must be distinguished from certification by D for eligibility in federal assistance programs. While JCAH accreditation may, depending on the circumstances, be a component of certification, the two are not necessarily coextensive. Ps had been the beneficiaries of three types of federally funded benefits: (1) Medicare, (2) Medicaid, and (3) Supplemental Social Security Income. When TPH was decertified in 1975, all of the benefits described above were terminated. The Children's Unit was reaccredited and thus recertified, however, their benefits were restored, since it was determined that the Unit had, standing alone, always been so qualified. Provision was made to pay out benefits that had been withheld in the interim period from December 21, 1975, to December 8, 1976. The benefits of patients in the Adult Unit, on the other hand, were not restored until the Unit regained its accreditation in 1981, and payments withheld from 1975 to 1981 were not paid retroactively. Ps brought suit alleging that the deprivation of their Medicare, Medicaid, and Social Security benefits was unconstitutional. They claimed a lack of procedural due process, lack of substantive due process, lack of equal protection, and unconstitutional delegation of authority to JCAH. The district court found that the termination of the federal benefits did not violate procedural or substantive due process, nor did it offend equal protection. It found that there was no unconstitutional delegation of authority to JCAH. P appealed.
Issues
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Holding & Decision
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Legal Analysis
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