Blevins v. Oregon Health Authority

When submitting a final administrative order, “an administrative agency must state its factual findings and articulate a ‘rational connection between the facts it finds and the legal conclusions its draws from them,’” in order to meet the substantial reason rule. Drew v. PSRB, 322 Or 491, 499-500, 909 P2d 1211 (1996).

Plaintiff sought review of a final order from the Division of Medical Assistance Programs (DMAP), who denied her request for prior authorization of an out-of-hospital birth. Plaintiff assigned error to DMAP’s letter of cancellation of a contested case hearing. On appeal, Plaintiff argued that when DMAP denied her request for prior authorization of the out-of-hospital birth, she was “statutorily entitled to a hearing about the denial,” regardless of whether she had signed any required forms or if she could personally be billed for services received. In response, Defendant argued that because Plaintiff did not sign the required ‘OHP Client Agreement to Pay for Health Services’ form with the out-of-hospital center, she could not be personally billed for services, which meant the “issue” on Plaintiff’s behalf was “no longer hearable.” When submitting a final administrative order, “an administrative agency must state its factual findings and articulate a ‘rational connection between the facts it finds and the legal conclusions its draws from them,’” in order to meet the substantial reason rule. Drew v. PSRB, 322 Or 491, 499-500, 909 P2d 1211 (1996). The Court of Appeals held that the letter from DMAP cancelling the hearing did not substantially explain why the hearable issues had been resolved and DMAP must explain their determination “in a manner that permits meaningful judicial review.” Reversed and remanded.