## Facts

- Jeanne Meyers, a mentally disabled adult with a speech handicap, lived in an Iowa residential care facility and received Supplemental Security Income, making her eligible for Iowa Medicaid.
- A speech pathologist recommended, and Meyers’s physician prescribed, an electronic speech device (HandiVoice 110) to assist her communication.
- Meyers requested that the Iowa Department of Human Services provide the HandiVoice 110 through Medicaid; the Department denied the request on the ground that electronic speech devices were not covered.
- During the case, a more expensive device (Vois Model 130) became available, and Meyers amended her request to seek that device in the alternative.
- Meyers supported summary judgment with affidavits from her physician and speech pathologist stating an electronic speech device was necessary and reasonable treatment for her condition.
- The Department opposed summary judgment with an affidavit stating a less expensive device (such as the Vocaid) could adequately meet Meyers’s needs and that the Department would provide a device in that price range.

## Issues

1. Whether summary judgment was proper where the parties offered conflicting evidence about which speech device, if any, was medically appropriate and required under Iowa’s Medicaid plan.
2. Whether the record permitted an order requiring the state to furnish a particular electronic speech device (HandiVoice 110 or Vois Model 130) under Medicaid.

## Decision

- The Eighth Circuit reversed the district court’s grant of summary judgment for Meyers and remanded.
- The court held that genuine issues of material fact remained regarding which speech device was appropriate for Meyers under Iowa’s Medicaid plan.
- Because the material facts were disputed, the district court erred in ordering the Department to furnish the HandiVoice 110 on the summary-judgment record.
- The court’s disposition left unresolved, on the existing record, whether any electronic speech device must be provided and, if so, which device.

## Legal Principles

- Summary judgment is improper when the record shows a genuine dispute of material fact on an outcome-determinative question, including the medical appropriateness of a requested treatment or device.
- In Medicaid benefit disputes, determining whether a particular item is required under a state plan may depend on individualized fact-finding, including competing medical and administrative evidence about adequacy of alternatives and cost.
- A state’s Medicaid obligations, as applied to a specific beneficiary’s requested equipment, may require development of a factual record sufficient to decide what the plan covers and what is medically appropriate for that beneficiary.

## Conclusion

The Eighth Circuit reversed and remanded because conflicting evidence about the adequacy of alternative speech devices created a material factual dispute, making it improper to compel provision of a specific electronic speech device on summary judgment.


Meyers ex rel. Walden v. Reagan, 776 F.2d 241 (8th Cir. 1985)