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Steimel v. Wernert (2016)

  • 1 day ago
  • 3 min read

By: Kacie Matthews



Overview


Steimel v. Wernert was a case decided by the United States Court of Appeals for the Seventh Circuit, involving the State of Indiana. The case involved state administration: The Indiana Family and Social Services Administration (FSSA) that operated and controlled the Aged and Disabled Medicaid Waiver. The Medicaid Waiver provided federally-approved home and community based services to those ages 65 and older, or with a disability, who require  more medical care, and fit the monthly financial aid limit caps. The given services included: personal care (assistance eating, dressing, and other everyday activities), housekeeping care (cleaning up client’s homes, and meal preparation), and case management (completion of personalized services). Until 2011, the Age and Disabled Medicaid Waiver had no financial cap, or limit. However, the Indiana Administration changed their policies, and made many disabled recipients of this program ineligible to receive the Medicaid Waiver; as a result, moving them over to the Family Support (FS) waiver. Unlike the Medicaid Waiver, the FS waiver was capped at an annual limit of $16,545, resulting in plaintiffs arguing that the given changes violated the Americans with Disabilities Act (ADA).



Summary


Plaintiffs in the case, who claimed that the new administrative and policy changes in The Indiana Family and Social Services Administration (FSSA) violated ADA included:

  1. Karla Steimel: Diagnosed with Cerebral Palsy

  2. Thomas Maertz: Diagnosed with Cerebral Palsy and Intellectual Disability

  3. Timothy Keister: Diagnosed with Intellectual Disability

  4. Michael Beckem: Diagnosed with Intellectual Disability

  5. Lois Beckem: Diagnosed with Down Syndrome 

All plaintiffs claimed that by having a capped annual limit for disability services, it violated the ADA Integration Mandate. The ADA Integration Mandate required all state and local governments to provide services and programs in the most integrated setting appropriate for qualified individuals with disabilities. Services, activities, and programs needed to be integrated into an appropriate setting for all those who required the home and community development necessity. With the Integration Act came restrictions on the changes that can and cannot be made within governments regarding the Medicaid Waiver. Unnecessary segregation and institutionalization is prohibited, as the main purpose was that all individuals with disabilities could live within a community. 


The Seventh Circuit ruled that the state of Indiana had indeed violated ADA, and by making changes to the administrative policies, they violated the institutional care that was required in the ADA Integration Mandate (placing individuals at risk of unnecessary institutionalization). The legal holdings and rulings by the Seventh Circuit argued that plaintiffs don’t need to wait until they are institutionalized before bringing suit against state administration if state actions place them at serious risk of institutionalization. Secondly, the state of Indiana argued that the change in policies was just an administrative change and wasn’t binding - although Indiana was moving all clients to another capped waiver. The Seventh Circuit stated that Indiana was attempting to escape liability by pushing false effects into the narrative. Thirdly, the Seventh Circuit argued that the Indiana Family and Social Services Administration was placing individuals with disabilities at risk of unnecessary isolation and restricting their ability to be part of their community and connection. 



Impact


Steimel v. Wernert established the consequences and overall results to the state's administrations changing policies that violate and confine individuals with disabilities. The decision strengthened protections against disability discrimination in the provision of Medicaid services.



Court Documents


Steimel v. Wernert, No. 15-2377 (7th Cir. 2016), vLex



Citations



 
 
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