Gist v. Atlas Staffing, Inc. et al.

Gist v. Atlas Staffing, Inc. et al., No. WC16-6019 (W.C.C.A. June 21, 2017).

This case concerns whether a Minnesota Compensation Judge has the authority to interpret and apply federal laws in determining the medical expenses claimed by intervenors.

In Gist, the Employee alleged work-related kidney failure because of exposure to silica sand while working at Waltek, Inc. through temporary assignment through Atlas Staffing, Inc. (the “Employer”). The Employer’s workers’ compensation claims were administered by Meadowbrook Claims Service (“Meadowbrook”). The Employer and Meadowbrook denied primary liability.

The Compensation Judge held that she lacked authority to interpret and apply Medicaid and Medicare laws in determining the medical expense claim asserted by Fresenius Medical Center (“Fresenius), one of the intervenors. Fresenius received Medicaid and Medicare payments for the Employee’s kidney treatment. It intervened into the litigation, and sought payment of the outstanding amount against the Employer and Meadowbrook—i.e., the Spaeth balance. The Employer and Meadowbrook argued that because Fresenius accepted payment from Medicaid and Medicare, its intervention claims were paid in full, and Fresenius could not seek the Spaeth balance.

The W.C.C.A. agreed with the Compensation Judge and concluded she lacked the authority to interpret and apply federal law implementing Medicaid and Medicare programs.  The W.C.C.A., however, modified the Compensation Judge’s decision to the extent that she ordered payments “be made ‘in accordance with all other state and federal laws.”’ In short, the W.C.C.A. concluded that the Compensation Judge lacked the authority to order compliance with any law outside of the Workers’ Compensation Statute.

In addition, the W.C.C.A., in affirming the Compensation Judge, concluded that intervenors who accept Medicare and Medicaid payments for treatment provided to injured employees are not foreclosed from obtaining outstanding payment for medical intervention interests.  Medical intervenors are not limited to amounts accepted from third-party payers, and are entitled to payment of medical charges for services provided to injured employees, up to the maximum allotted amounts under the applicable fee schedule.

The core takeaway of this case turns on how Compensation Judges only have subject matter jurisdiction over questions of law and fact arising under the Workers’ Compensation Statute. The W.C.C.A. explicitly held that this jurisdiction does not extend to interpreting or applying laws outside the workers’ compensation system.