OAH 16-1800-20298-2

 

STATE OF MINNESOTA

OFFICE OF ADMINISTRATIVE HEARINGS

 

FOR THE COMMISSIONER OF HUMAN SERVICES

 

 

In the Matter of the SIRS Appeal of TenderCare Home Services, Inc.

RECOMMENDATION FOR

SUMMARY DISPOSITION

 

            This matter is before Administrative Law Judge Manuel J. Cervantes (ALJ) on the Department of Human Services’ (Department or DHS) Motion for Summary Disposition.  On March 5, 2009, DHS served a Notice of and Order for Hearing and Prehearing Conference (Notice) on TenderCare Home Services, Inc. (Respondent or TenderCare) by U.S. mail.  The Notice scheduled a prehearing conference for April 13, 2009. 

 

Corrie A. Oberg, Assistant Attorney General, Bremer Tower, Suite 900, 445 Minnesota Street, St. Paul, Minnesota 55101-2130, appeared on behalf of the DHS. 

 

Amadu Edward Swaray, Esq., 5701 Shingle Creek Parkway, Brooklyn Center, MN 55430, appeared on behalf of the Respondent at the prehearing conference and replied to DHS’s Motion.

 

During the course of the prehearing conference, the parties agreed that they wished to proceed by summary disposition.  The parties agreed to a briefing schedule and the ALJ issued a Scheduling Order, dated April 14, 2009. A Second Scheduling Order, accommodating the Summary Disposition Motion and reserving a hearing schedule was issued on July 1, 2009.

 

DHS filed its Motion with the Office of Administrative Hearings on July 6, 2009.  Respondent filed its Memorandum in Opposition to the Motion on July 20, 2009.  The record closed on July 28, 2009, upon receipt of DHS’s reply.

 

STATEMENT OF ISSUE

 

            The issue in this case is whether DHS is entitled to recover Medical Assistance (MA) payments totaling $113,909.92 made to TenderCare for home care services rendered between August 1, 2007 and March 31, 2008.

 

            Based upon all of the files, records and proceedings herein, and for the reasons set forth in the accompanying Memorandum, the ALJ makes the following:

 


RECOMMENDATION

 

            1.         That the DHS’s Motion for Summary Disposition be GRANTED; and

 

            2.         That the Commissioner of Human Services (“Commissioner”) AFFIRM DHS’s recovery of $113,909.92.

 

 

Dated:  August 26, 2009

_s/Manuel J. Cervantes____

MANUEL J. CERVANTES

Administrative Law Judge

 

NOTICE

 

            This report is a recommendation, not a final decision.  The Commissioner will make the final decision after a review of the record and this report.  The Commissioner may adopt, reject, or modify this Report and Recommendations. 

 

Under Minn. Stat. § 14.61, the Commissioner may not make a final decision until after the parties have had access to this report for at least 10 days.  During that time, the Commissioner must give any party adversely affected by this report an opportunity to file objections to the report and to present argument supporting its position.  Parties should contact Cal Ludeman, Commissioner of Human Services, P.O. Box 64998, St. Paul, MN 55164-0998, (651) 296-2701, to learn the procedure for filing exceptions or presenting argument.

 

            The record of this proceeding closes upon the filing of exceptions to the report and the presentation of argument to the Commissioner, or upon the expiration for doing so.  The Commissioner must notify the parties of the date on which the record closes.  If the Commissioner fails to issue a final decision within 90 days of the close of the record, this report will constitute the final agency decision.

 

            Under Minn. Stat. § 14.62, subd. 1, the Commissioner is required to serve his final decision upon each party and the ALJ by first class mail or as otherwise provided by law.  

 

MEMORANDUM

 

I.          Jurisdiction

 

The ALJ and DHS have jurisdiction pursuant to Minn. Stat. §§ 14.50 and 256B.04, subds. 15(c).  The Respondent was given notice of the hearing in this matter and DHS has complied with all relevant procedural requirements.


 

ll.         Contention of the Parties

 

            This is an appeal by Respondent from DHS’s Notice of Agency Action, dated April 29, 2009[1], indicating that DHS intended to recoup an overpayment of Minnesota Health Care Program (MHCP) funds.[2]  DHS based its proposed action on Respondent’s failure to comply with the documentation requirements in support of billed services contained in Minn. R. 9505.2175, subp. 1.[3]  Respondent contends that it did not know of these requirements, and in any event, it substantially complied with the documentation rules.[4]

 

lII.        Procedural Standard

 

Minn. R. Civ. P. 56 provides that summary judgment shall be granted if “there is no genuine issue as to any material fact and that either party is entitled to a judgment as a matter of law.”[5]  Summary disposition is the administrative equivalent of summary judgment in district court practice.  Summary disposition is appropriate where there is no genuine issue as to any material fact and one party is entitled to judgment as a matter of law when the law is applied to those undisputed facts.[6]  The Office of Administrative Hearings has generally followed summary judgment standards developed in judicial courts when considering motions for summary disposition in contested case matters.[7]  A genuine issue is considered one that is not frivolous or a sham, and a material fact is one whose resolution will affect the result or outcome of the case.[8] 

 

A moving party has the initial responsibility of showing no material fact is in dispute. To successfully resist a motion for summary judgment, the nonmoving party must show that there are specific facts in dispute that have a bearing on the outcome of the case.[9]  When considering a motion for summary judgment, the Court must view the facts in the light most favorable to the non-moving party.[10]  All doubts and factual inferences must be resolved against the moving party.[11]  Although all doubts and factual differences must be resolved in favor of the non-moving party, the party opposing the motion must establish by substantial evidence that there exists a genuine issue of material fact.[12]  The ALJ is to make a recommendation about the appropriate interpretation of the law and about how that law applies to the undisputed facts.

 

IV.       Legal Background

 

In Minnesota, the Medicaid program is jointly funded with the federal government and administered by DHS.[13]  The purpose of Medicaid is to provide necessary medical assistance to certain individuals whose income and resources are insufficient to meet the cost of the medical care they need.[14]  Because of this funding arrangement, Minnesota must comply with federal statutes and regulations of the U.S. Department of Health and Human Services’ Centers for Medicare and Medicaid, including the implementation of a surveillance and utilization control program to safeguard against “unnecessary or inappropriate use of Medicaid services and against excess payments”.[15]  Under federal law, the states must conduct post-payment reviews on a random basis to discover and correct inappropriate use of Medicaid payments.[16] 

 

In response to its federal obligation, DHS created the Surveillance and Integrity Review Section (SIRS) and promulgated Minnesota R. 9505.2160 to 9505.2245 (2008) to address the inappropriate use of Medicaid payments.  SIRS is charged with investigating providers for compliance with federal and state statutes, rules, and regulations[17].  SIRS conducts post-payment review of claims submitted for Minnesota MA payments.[18]  SIRS may select provider claims for review at random or based on a suspicion of fraud or improper payment[19] and may examine the providers’ health service or financial records with 24-hour notice.[20]  Under Minnesota law, DHS may impose sanctions on a provider and/or may recover inappropriate payments when it discovers that a provider has inappropriately billed Minnesota MA.[21]  Upon completion of an investigation, SIRS has discretion to pursue criminal, civil, or administrative action.[22]  DHS commences its action to collect inappropriate payments or impose sanctions by issuing a Notice of Agency Action to the provider.[23]  A provider who disputes the proposed agency action may request an appeal.[24] 

 

V.                 Undisputed Facts

 

On October 27, 2006, DHS instituted the use of a new timesheet for PCA providers.  All Minnesota licensed personal care attendants (PCA) providers were notified of the required use of the timesheet in October and December 2006.[25]  The notice of December 22, 2006 provided that PCA must use the approved timesheet, effective April 1, 2007.

 

On October 16, 2007, Respondent executed a Provider agreement, signed by Jenifer Malobe (Malobe) as C.E.O.  The Agreement states that Respondent would maintain records that fully disclose the extent of services provided to individuals under MHCP, specifically, in accordance with Minn. R. 9505.2160 through 9505.2245 as well as all federal and state law relating to the delivery of services and submission of claims for such services, and to assume full responsibility for the accuracy of claims submitted to DHS.[26] 

 

Respondent was selected for an audit after DHS received emails from Malobe, the president, owner, and PCA, indicating that she had submitted claims under her treating provider number for services she did not provide.[27]  Malobe communicated via email with a DHS representative that she was unable to submit claims using the treating provider numbers of three of her employees who had provided services, so she submitted the claims under her own treating provider number.  On April 1, 2008, DHS notified Respondent that a record review would be conducted the next day at Respondent’s place of business.[28]

 

On April 2, 2008, Susan Kurysh (Kurysh) and Tom Dybvik (Dybvik), SIRS Investigators, appeared at Respondent’s place of business to conduct their review.[29]  The PCA timesheets submitted for review by Respondent showed that the PCA services billed under Malobe’s treating provider number for the dates in question were actually provided by Respondent’s employees, Tubeah Vonziah, Fatuma Fahbulleh, and Fortee Williams.[30]  Malobe did not provide documentation to support that the PCA services billed under her provider number for the dates from August 1, 2007 to March 31, 2008 were actually provided by her.[31]  Respondent did not use the Department-approved timesheet nor did Respondent submit its timesheet for DHS approval.[32]  The timesheets used by Respondent did not contain much of the required information mandated by Minn. R. 9595.2175.[33]

 

On April 2, 2008, Respondent produced the timesheets of eight of its PCA employees in support of its claimed billing.  They are represented in Exhibits 2-4 and 9-13.

 

On April 2, 2008, Respondent produced the timesheets of a nursing employee, George Safo, in support of its claimed billing.[34]  Service recipient Grace Mattson received both Registered Nursing (RN) and Licensed Practical Nursing (LPN) services during the time period under review but no timesheets, or other documents, for LPN services were submitted by Respondent at the April 2, 2008 review in support of the LPN claimed billing.  Based upon the review of nursing documentation submitted by Respondent on April 2, 2008, DHS determined that Respondent failed to support the level of service or the number of units billed for nursing services. 

 

DHS issued its Notice of Agency Action to Respondent on April 29, 2008, seeking recovery of an overpayment in the amount of $51,350.24 for PCA services and in the amount of $62,559.68 for nursing services, for a total overpayment of $113,909.92.[35]  Attached to the Notice of Agency Action was a document which itemized the total overpayment sought.[36]  The grounds for recovery of the overpayment was “[l]ack of documentation to support the billed services”, fraud was not alleged.

 

On May 9, 2008, Malobe contacted Kurysh and requested an informal meeting to discuss the investigation. Malobe informed Kurysh that she had additional documentation to submit.[37]  DHS staff met with Malobe and her husband on May 15, 2008.  Malobe submitted additional documents, including computer print-outs listing dates and hours worked by Respondent’s staff, including summaries from LPNs Bangura and Orina  and bearing the signatures of the recipients.[38]

 

On May 21, 2008, DHS sent the Respondent a letter indicating that the entire amount of the $113,909.92 overpayment remained due as originally stated in the Notice of Agency Action of April 29, 2008[39] because, as before, DHS advised that the additional documents did not satisfy the documentary requirements of Minnesota law. Respondent timely filed its appeal of the agency action on May 23, 2008.[40]

 

VI.               Analysis

 

The facts in this case are not in dispute; both parties have relied on the same documents to make their respective arguments.  The documents comprise the facts in this case and as such, there is no genuine material question of fact.  Where there is a question as to the facts, the ALJ has viewed them in the light most favorable to the Respondent.  The ALJ is charged with applying Minnesota law and rules to these facts and making a recommendation to the Commissioner of Human Services. 

 

Respondent has taken the legal position that it has substantially complied with the documentation requirements contained in Minnesota rules and that because it did not know of the documentation requirements for billing, full compliance is not necessary.  Ignorance of the law is no excuse.  Respondent signed her name to the Provider agreement with DHS on October 16, 2007 where it specifically states, that she agrees “[t]o maintain records that fully disclose the extent of services provided to individuals under thee programs in accordance with Minnesota Rules, parts 9505.2160 to 9505.2245.”  Given her signature, she knew or should have known of the requisite obligations to document under the rules.    

 

Respondent’s legal posture presents a legal question, to wit, whether substantial compliance is sufficient to satisfy the documentary requirements of Minn. R. 9050.2175.  For the reasons stated below, the ALJ cannot conclude that Respondent substantially complied with the rules.  But even if the ALJ did, Respondent did not cite any legal precedent that permits the use of “substantial compliance” as the legal standard.  The ALJ finds as a matter of law that substantial compliance is not compliance with Minnesota law and, therefore, DHS is entitled to summary disposition in its favor.

 

The legal standard to be employed by the ALJ is found in Minn. R. 9505.2160 through 9505.2245. 

 

Minn. R.9505.2175, Subp. 1, states,

 

[a]s a condition for payment by a program, a vendor must document each occurrence of a health service provided to a recipient. The health service must be documented in the recipient's health service record as specified in subpart 2 and, when applicable, subparts 3 to 9. Program funds paid for a health service not documented in a recipient's health service record shall be recovered by the department.

 

Subp. 2., requires a vendor to keep a health service record for all health services, including nursing, that contain

(1)               the recipient’s name on each page of the recipient’s record;

(2)               the date on which the entry is made;

(3)               the date or dates on which the health service is provided;

(4)               the length of time spent with the recipient if the amount paid for the service depends on time spent;

(5)               the signature and title of the person from whom the recipient received the service; and

(6)               when applicable, the countersignature of the vendor or supervisor as required under parts 9505.0170 to 9505.0475.

Failing to develop and maintain health service records as required above constitutes abuse.[41]  The Commissioner is required to seek monetary recovery of funds received through abuse.[42]

A.        Nursing Hours Claimed and Billed.  

The nursing documentation provided by Respondent on April 2, 2008 is divided into three types of documents designated[43]:  “Nurse’s Notes”:  from 11/2/2007 through 2/29/2008 consisting of nine pages[44]; “Progress Notes:  from 9/15/07 through 2/3/08 consisting of two pages[45]; and “Monthly Charting”:  from 9/2/07 through 12/2/07 consisting of six pages for services provided to recipient Grace Matteson (Matteson). 

 

None of these documents contain the length of time spent with Matteson.  While there appear to be signatures and titles of the persons who provided the service, most signatures and titles are illegible as are the notes themselves.  Some of the entries note the time of day, but none of the notes indicate the time nursing services began or ended.  Five of the documents do not contain Matteson’s name.  Because of these inadequacies, it is impossible to calculate the amount of time the nurse spent with the recipient.  The documents for nursing services do not provide sufficient documentation to support the level of service provided or the number of units billed.  These documents do not comply with the requirements of Minn. R. 9505.2175, subp. 2 cited above.

Respondent also submitted timesheets for its RN employee, George Safo, to support its billing claim.[46]  These documents represent biweekly periods from August 8, 2007 through March 23, 2008 for services provided to Matteson.[47]  There are 16 timesheets representing 222 days worked.[48]  Of the 222 days worked, there are only about 48 days of health status entries made by Safo regarding Matteson’s health in the nursing records referenced above.  This leaves open the question of what other health services were provided to Matteson the remaining 174 days claimed and billed for. These documents, in combination with the nursing documents referenced, above do not provide sufficient documentation to support the level of service provided or the number of units billed.  These documents do not comply with the requirements of Minn. R.9505.2175, subps. 1 or 2 cited above.

Respondent submitted a second batch of documents at the May 15, 2008 informal meeting.[49]  These documents represent monthly summaries of dates and times worked by various employees of Respondent.  They add a new element in that they are signed by the Matteson.  The thirteen pages of documents representing the period from August 7, 2007 through March 31, 2008 for employee Safo’s service to Matteson total 238 days.  These documents are not consistent with the 222 days claimed on his timesheets referenced above.  These documents do not list the services provided to the Matteson; do not list the total number of service hours provided to the Matteson; and the timesheets do not bear the provider’s signature.  These documents are not compliant with the requisite elements of Minn. R. 9505.2175, subps. 1 or 2 cited above.

As stated above, Respondent submitted no timesheets whatsoever for LPN employees at the April 2 review.  The only LPN health notations in the record are one Nurse’s Note entered on “2-22-08” and two Progress Notes dated “2-1-08” and “2-3-08”.[50]  At the May 15 meeting, Respondent produced three months of summaries for LPN Alice Bengura; from November 2007 through January 2008.[51]  These summaries indicate that Bengura worked every day of each month for a total of 92 days. 

Respondent also submitted summaries for LPN Daniel Orina; from February through March 2008.  These summaries indicate that Orina worked every day of each month for a total of 60 days.  Of the 152 days worked by LPNs from November 2007 through March 2008, there are only 3 days of health status entries made by LPNs regarding Matteson’s health in the nursing records referenced above.  Again, this leaves open the question of what LPN health services were provided to Matteson the remaining 149 days claimed and billed for.  The LPN documents referenced above do not provide sufficient documentation to support the level of service provided or the number of units billed.  These documents do not comply with the requirements of Minn. R.9505.2175, Subps. 1 or 2 cited above.

Respondent’s failure to maintain the records required by Minn. R. 9505.2175 constitutes abuse under Minn. R. 9505.2165 and requires the Commissioner to seek monetary recovery under Minn. R. 9505.2215.  DHS is entitled to recover the $62,559.68 paid to Respondent for nursing services.

B.        PCA Hours Claimed and Billed.

The following documentation must be made for each day that care is provided by each PCA who provides care to the recipient[52], in addition to the requirements of Minn. R. 9505.2175, subpts. 1 and 2 referenced above:

(1)              the recipient's name; (2) the name of the personal care assistant providing services; (3) the day, month, and year the personal care services were provided; (4) the total number of hours spent providing personal care services to the recipient; (5) the time of arrival at the site where personal care services were provided and the time of departure from the site where services were provided, including a.m. and p.m. designations; (6) the personal care services provided; (7) notes by the personal care assistant regarding changes in the recipient's condition, documentation of calls to the supervising qualified professional, and other notes as required by the supervising qualified professional; (8) the personal care assistant's signature on the time sheets which record the hours worked by the personal care assistant, and must contain the following statement: "I certify and swear that I have accurately reported on this time sheet the hours I actually worked, the services I provided, and the dates and times worked. I understand that misreporting my hours is fraud for which I could face criminal prosecution and civil proceedings"; and (9) the recipient's signature, stamp, or mark, or the responsible party's signature, if the recipient requires a responsible party.

In reviewing the PCA documents submitted by Respondent at the April 2 review[53], the documentation did not contain all the required information.  The ALJ observes that none of the timesheets contain the recipients name or signature, the personal care services provided, notes by the PCA regarding changes in the recipient’s condition, or the language certifying accuracy of hours.  The records of three PCAs lacked the total hours on site or worked; the records of two PCAs lacked the day, month, and/or year service was provided; and two PCAs failed to sign all their timesheets.[54]

The PCA summaries[55] submitted by Respondent at the May 15 meeting do not comply with Minn. R. 9505.2175, subpt. 7(H), cited above.  They do not contain the list of services provided to the recipient, do not list the total number of hours services were provided to the recipient, and do not bear the PCA’s signature.

Further comparison of the timesheets submitted on April 2 with the summaries submitted on May 15 reveal additional inconsistencies, i.e., for PCA Vonziah[56], Respondent submitted 4 timesheets representing biweekly periods ending Saturday, September 23, 2007[57] to November 18, 2007[58].  There were no timesheets submitted for this employee for the balance of November or December 2007, yet Respondent claimed additional hours for this employee in the summary submissions. 

The November 1-30, 2007 summaries[59] are inconsistent with the timesheet, dated 11-30-07.  The summaries[60] reflect that employee worked 24 hours from 11/11/07 through 11/13/07, but the timesheet submitted for this period reflect no hours earned.  The timesheet signed by employee on 11/30/07 reflects 28 hours earned for the period from 11/11/07 through 11/30/07, but the summaries[61] reflect 91 hours earned for the same period by this employee.  The December 1-30, 2007[62] summaries[63] for this employee reflect 143 hours worked during this month, but no concurrent timesheets were provided to support these hours. 

Finally, there is a serious question whether Vonziah was eligible for reimbursement for any work prior to January 2008 because her provider number did not become effective until January 1, 2008; allegations that were unanswered by Respondent.[64] Notwithstanding DHS’s representative advising Malobe on March 17, 2008 that PCA services provided before a background check was completed were not eligible for payment, Respondent submitted documentation requesting PCA payments for ineligible time periods.

Even after DHS afforded Respondent a second opportunity to submit a complete record of documentation, Respondent’s documentation system simply does not comply.  Respondent’s failure to maintain the records required by Minn. R. 9505.2175 constitutes abuse under Minn. R. 9505.2165 and requires the Commissioner to seek monetary recovery under Minn. R. 9505.2215.  DHS is entitled to recover the $51,350.24 paid to Respondent for PCA services.

Finally, Malobe submitted hours for payment for which she clearly did not provide the services and this also meets the technical definition of abuse under the rules and serves as an additional ground for DHS to seek monetary recovery for overpayments.

            The ALJ recognizes that this is onerous result but Respondent contributed to it by delaying its submission for payment for claimed services for seven months.  Had Respondent submitted for payment sooner, it would have learned that its documentation practices were noncompliant, it could have rectified its documentation system sooner, and the overpayment may have been less.  Of course, the better practice would simply have been to inquire of DHS as to what the documentation requirements for payments were, implement documentation systems that were Minnesota rule compliant, and to have avoided this inquiry altogether.

 

M. J. C.



[1] Notice of Agency Action; Ex. 16.

[2] MHCP is an umbrella term that includes all Department administered health care programs; Susan Kurysh Aff., Senior Investigator with the office of Surveillance and Integrity Review.

[3] Notice of Agency Action; Ex. 16. 

[4] Minn. R. 9050.2165, 9050.2175 and 9050.2215.

[5] Minn. R. Civ. P. 56.03 (1994); Sauter v. Sauter, 70 N.W.2d 351, 353 (Minn. 1995); Louwegie v. Witco Chemical Corp., 378 N.W.2d 63, 66 (Minn. App. 1985); Minn. R. 1400.5500K

[6] Sauter v. Sauter, 70 N.W.2d 351, 353 (Minn. 1955); Louwagie v. Witco Chemical Corp., 378 N.W.2d. 63, 66 (Minn. App. 1985); Minn. R. 1400.5500, K; Minn. R. Civ. P. 56.03. 

[7] See Minn. R. 1400.6600 (2007).

[8] Illinois Farmers Insurance Co. v. Tapemark Co., 273 N.W.2d 630, 634 (Minn. 1978); Highland Chateau, Inc. v. Minnesota Dept. of Public Welfare, 356 N.W.2d 804, 808 (Minn. App. 1984). 

[9] Thiele v. Stitch, 425 N.W.2d 580, 583 (Minn. 1988); Hunt v. IBM Mid America Employees Federal, 384 N.W.2d 853, 855 (Minn. 1986).

[10] Ostendorf v. Kenyon, 347 N.W.2d 834 (Minn. App. 1984).

[11] See, e.g., Thompson v. Campbell, 845 F. Supp. 665, 672 (D. Minn. 1994); Thiele v. Stich, 425 N.W.2d 580, 583 (Minn. 1988); Greaton v. Enich, 185 N.W.2d 876, 878 (Minn. 1971).

[12] Osborne v. Twin Town Bowl, Inc., 749 N.W.2d 367, 371 (Minn. 2008) (citing Anderson v. State Dep’t of Natural Res., 693 N.W.2d 181 (Minn. 2005).

[13] Title XIX of the Social Security Act, 42 U.S.C. § 1396 (2007), Minn. Stat.ch.256B (2008).

[14] 42 U.S.C. § 1396 (2006); Arkansas Dept. of Health and Human Services v. Ahlborn, 547 U.S. 268, 275, 126 S.Ct. 1752, 1758 (2006).

[15] 42 C.F.R. § 456.3(a) (2009).

[16] 42 C.F.R. § 456.23 (2009).

[17] Minn. R. 9505.2160, subp. 1 (2008); Kurysh Aff.

[18] MA is the predominant program of the MHCP Department-administered health care programs; Kurysh Aff.

[19] Id.

[20] Minn. R. 9505.2200, subp. 3(A); 9505.2185, subp 2 (2008).

[21] 42 C.F.R. § 456.725 (2009); Minn. Stat. § 256B.04, subd. 4 and 15(a) (2008); MA is the predominant program of the MHCP Department-administered health care programs; Kurysh Aff.

[22] Minn. R. 9505.2200, subps. 4 and 5 (2008).

[23] Minn. R. 9505.2230, subp. 1 (2008).

[24] Minn. Stat. § 256B.04, subd. 15(c) (2008); Minn. R. 9505.2245, subp. 1 (2008).

[25] Kurysh Aff.; Exs. 5 and 6.

[26] Id. and Ex.7.

[27] Kurysh Aff.

[28] Id.

[29] Id.

[30] Id.; Exs. 2, 3, and 4.

[31] Id.

[32] Id.

[33] Id., compare Exs. 2, 3, and 4 with the approved Department timesheet, Ex. 8.

[34] Ex. 15.

[35] Id.; Ex 16.

[36] Ex. 16; Attachment A.

[37] This raises a question about credibility:  Kurysh states in her affidavit that at the conclusion of the review on April 2, 2008, she asked Malobe if the documents presented at that meeting were the complete record for each recipient.  Kurysh states that Malobe replied it was. On May 9, when Malobe requested the informal meeting with the Department, Kurysh states that she asked Malobe whether she had additional documentation to submit, Malobe replied that she did.  When Kurysh asked whether the documentation was available at the time of the review, Malobe said it was, but that the investigators had not requested it.  The standard in a summary disposition is that the facts will be viewed in the light most favorable to the non-moving party, Respondent herein, and therefore, explains how the ALJ arrived at the facts as stated above.

[38] Kurysh Aff.; Ex. 17.

[39] Id.; Ex. 18.

[40] Id.; Ex. 19.

[41] Minn. R. 9505.2165, subp. 2 (7).

[42] Minn. R. 9505.2215

[43] Ex. 14.

[44] Respondent provided Nurse’s Notes dated 11/3/07 (the 10/24/08 entry was scratched out and the 11/3/07 entry was substituted for it) through 9/28/08.  The period of payments under review is from August 2007 through March 2008 and therefore, the Nurse’s Notes dated after March 31, 2008 are beyond the scope of this review and were not considered by the ALJ as support for payment for the relevant period.

[45] The ALJ considered the Progress Note dated 9/15/08 because the entry immediately below it is dated is 9/17/2007, the 8 was scratched out and overwritten with the “7”.  No yearly date is noted for the 4 entries immediately below this entry.

[46] Ex. 15.

[47] While the last timesheet represents the period of 3/10 through 3/23/2008, Malobe and Safo signed and dated the timesheet 3/7/08.

[48] The timesheets contain discrepancies, i.e., the timesheet dated 1/30/2008 does not bear a “time in” time for the entire week of 1/24 thru 1/30/2008.  Similarly, there is no “time in” time on 9/10/07, yet both timesheets bear the signatures of Malobe and Safo.

[49] Ex. 17.

[50] Ex. 14; the signatures are not legible but it is clear that these are LPN entries.

[51] Ex. 17.

[52] Minn. R. 9505.2175, subp. 7(H) (2008).

[53] Exs. 2-4 and 9-13.

[54] Kurysh Aff.

[55] Ex. 17.

[56] Ex. 2.

[57] Timesheet signed by employee on 9/28/07.

[58] Timesheet signed by employee on 11/30/07.

[59] Ex. 17; signed by recipients Matteson on 12/3/07 and Petersen on 12/5/07.

[60] Id.

[61] Id.

[62] Id., signed by Matteson but date is illegible.

[63] Ex. 17; Petersen and Matteson summaries.

[64] Ex. 17; emails between Respondent and Tonya Jackson, Department Representative.