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Thomason v. Department of Health and Social Services

HEALTH LAW
Supreme Court of Alaska (2025)
Ben Helzner

In Thomason v. Department of Health and Social Services, 563 P.3d 586 (Alaska 2025), the Supreme Court of Alaska held that Medicaid providers have a protected liberty interest in their reputations that the state deprives when it terminates providers, and therefore the state can only deprive that interest with due process. (Id. at 597–98). Thomason was a personal care assistant paid by Medicaid to provide direct services to her stepson. (Id. at 590). The Department of Health and Social Services (Department) investigated Thomason for inaccurate records of services, and found evidence that her records were indeed inaccurate. (Id. at 590–91). The Department then notified Thomason that her status as a personal care assistant would be terminated, and that she had a right to appeal this decision. (Id. at 592). Thomason appealed to the Office of Administrative Hearings, and an administrative law judge affirmed the Department’s decision. (Id.). Thomason then appealed to the Alaska superior court, arguing, among other things, that the administrative procedure did not provide sufficient due process to protect her liberty interest in her reputation. (Id. at 593). The superior court rejected this claim on the basis that the Department’s decision to terminate reflected on Thomason’s professional, rather than personal or moral character. (Id. at 597). However, the Supreme Court of Alaska reversed the superior court on this issue, reasoning that the court had previously recognized harms to reputational interests based on negative government job evaluations where the evaluated employee’s honesty, integrity, or morality was criticized. (Id. at 597). Thomason’s dismissal allowed the inference that she had committed some act or omission warranting such dismissal from a position of trust. (Id. at 598). The Supreme Court of Alaska held that Medicaid providers have a protected liberty interest in their reputations that the state deprives when it terminates providers, and therefore the state can only deprive that interest with due process. (Id. at 597–98).

Thomason v. Department of Health and Social Services

HEALTH LAW
Supreme Court of Alaska (2025)
Ben Helzner

In Thomason v. Department of Health and Social Services, 563 P.3d 586 (Alaska 2025), the Supreme Court of Alaska held that Medicaid providers have a protected liberty interest in their reputations that the state deprives when it terminates providers, and therefore the state can only deprive that interest with due process. (Id. at 597–98). Thomason was a personal care assistant paid by Medicaid to provide direct services to her stepson. (Id. at 590). The Department of Health and Social Services (Department) investigated Thomason for inaccurate records of services, and found evidence that her records were indeed inaccurate. (Id. at 590–91). The Department then notified Thomason that her status as a personal care assistant would be terminated, and that she had a right to appeal this decision. (Id. at 592). Thomason appealed to the Office of Administrative Hearings, and an administrative law judge affirmed the Department’s decision. (Id.). Thomason then appealed to the Alaska superior court, arguing, among other things, that the administrative procedure did not provide sufficient due process to protect her liberty interest in her reputation. (Id. at 593). The superior court rejected this claim on the basis that the Department’s decision to terminate reflected on Thomason’s professional, rather than personal or moral character. (Id. at 597). However, the Supreme Court of Alaska reversed the superior court on this issue, reasoning that the court had previously recognized harms to reputational interests based on negative government job evaluations where the evaluated employee’s honesty, integrity, or morality was criticized. (Id. at 597). Thomason’s dismissal allowed the inference that she had committed some act or omission warranting such dismissal from a position of trust. (Id. at 598). The Supreme Court of Alaska held that Medicaid providers have a protected liberty interest in their reputations that the state deprives when it terminates providers, and therefore the state can only deprive that interest with due process. (Id. at 597–98).