Ken Paxton, Attorney General of the State of Texas v. Texas Department of State Health Services
The Attorney General appealed a district court's summary judgment in favor of the Texas Department of State Health Services regarding a Public Information Act (PIA) dispute. The Department sought to withhold information from an Office of Inspector General (OIG) investigation into employee misconduct, asserting confidentiality under Government Code section 531.1021(g). The Attorney General contended that this statutory confidentiality exception only applies to OIG audits or investigations related to Medicaid or other health and human services fraud, abuse, or overcharges. The appellate court, reversing the lower court's decision, agreed with the Attorney General's narrower interpretation. Consequently, the court held that the OIG's confidentiality under section 531.1021(g) is limited to audits and investigations concerning fraud, waste, and abuse within the provision and delivery of health and human services.