Justia U.S. D.C. Circuit Court of Appeals Opinion Summaries

Parents of B.D. filed suit against the District, challenging the adequacy of a compensatory education award and seeking to enforce other portions of the Hearing Officer's Decision, as well as to require the District to secure a therapeutic residential placement. The district court granted summary judgment in favor of the District. The court concluded that the parents have met their burden of demonstrating that the Hearing Officer, affirmed by the district court, was “wrong,” as he failed to award sufficient compensatory education to put B.D. in the position he would be in absent the free appropriate public education (FAPE) denial; neither 20 U.S.C. 1415(i)(2)(A) nor 28 U.S.C. 1331 provides a cause of action for parents seeking to enforce a favorable hearing officer decision; and the district court correctly held that the request for an injunction - the only relief count three specifically sought - had become moot. Accordingly, the court affirmed in part, reversed in part, and remanded in part. View "B.D. v. District of Columbia" on Justia Law

The Hospital challenged the method used by the Secretary to calculate its reimbursement for services it provided during 2003 and 2004 - the two years after statutory caps on reimbursements for psychiatric hospitals expired but before psychiatric hospitals were moved to a prospective-payment system. The court affirmed the district court's denial of the hospital's motion for summary judgment and grant of HHS's cross-motion for summary judgment because HHS’s interpretation was not only reasonable but also the best interpretation of the controlling statute, 42 U.S.C. 1395ww, and regulation, 42 C.F.R. 413.40. View "Washington Regional Medicorp v. Burwell" on Justia Law

This case arose from the Secretary’s decision in 2005 to change the boundaries of the geographic areas used to compute regional wage indices. A group of hospitals challenged the Secretary's decision to include wage data from Southcoast campuses outside the Boston-Quincy area in calculating the index for that area for fiscal years 2006 and 2007. The court concluded that the Secretary's treatment of Southcoast hewed to the existing administrative treatment of such multi-campus hospital groups; there were substantial informational and operational obstacles to implementing a different computational method quickly in 2006 or retroactively; appellants admit that the temporary effect of Southcoast’s multi-campus data on the wage index was a “one-off” occurrence arising from “unusual circumstances” that apparently did not affect any other multi-campus hospital group’s treatment; and nothing in the Medicare Act, 42 U.S.C. 1395 et seq., or established principles of administrative review mandate that the Secretary individually tailor one hospital’s reporting treatment to fit appellants' preferred computational outcome. Accordingly, the court affirmed the judgment. View "Anna Jacques Hospital v. Burwell" on Justia Law

Plaintiffs, Medicaid recipients who unsuccessfully sought coverage for prescription drugs, filed suit contending that the District and its officials unlawfully failed to afford them notice of their entitlement to a hearing before denying their prescription drug claims. The court affirmed the district court's dismissal of plaintiffs' claims under Title XIX of the Social Security Act, 42 U.S.C. 1396 et seq., and rejected plaintiffs’ argument that Title XIX’s notice regulations are triggered whenever there has been a denial of a claim for prescription drug coverage at the point-of-sale. However, the court reversed the district court's dismissal of the due process claims because the prescription drug coverage sought by plaintiffs qualifies as a property interest protected by the Fifth Amendment; plaintiffs adequately alleged that Xerox, a private company, determined their eligibility for benefits while acting as an agent of the District; and the court remanded the case to permit the district court to conduct an inquiry in the first instance into what process is due. The court also remanded to the district court to reconsider its jurisdiction over the D.C. -law claims in light of the court's partial reversal. View "NB v. District of Columbia" on Justia Law

The parent of K.E., a student who was diagnosed with several learning issues, seeks reimbursement under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., after she chose a private boarding school for K.E. The hearing officer and the district court denied reimbursement because, in their view, the child had no need to be in a residential program. The court concluded, however, that all statutory, regulatory, and judicial requirements for reimbursement of the costs of private school have been satisfied: the school district failed to offer the child a “free appropriate public education” in either a public school or a non-residential private school; the private boarding school the parent selected was, at the time, the only one on the record “reasonably calculated to enable the child to receive educational benefits” designed to meet the child’s needs; the residential component of the private school was in fact “necessary to provide a free appropriate public education to” the child; and the school district has not shown that the parent acted unreasonably. Accordingly, the court reversed and remanded for further proceedings. View "Leggett v. District of Columbia" on Justia Law

The Medicare program provides federally funded healthcare to the elderly and the disabled. See Title XVIII of the Social Security Act, 42 U.S.C. 1395. Under a “complex statutory and regulatory regime” called Medicare Part A, the Government reimburses participating hospitals for care that they provide to inpatient Medicare beneficiaries. Most hospitals are reimbursed for inpatient hospital services pursuant to a standardized rate, but the Social Security Act also provides a method for calculating reimbursement rates for certain rural hospitals that qualify as “sole community hospital[s]” (SCHs) or that qualify as “medicare-dependent small rural hospital[s]” (MDHs). SCHs and MDHs receive reimbursement based on either the standard rate or a hospital-specific rate derived from its actual costs of treatment in one of the base years specified in the statute, whichever is higher. MDHs and SCHs challenged revisions to the rules covering their Medicare reimbursements for inpatient hospital services, arguing that the Medicare statute forbids the Secretary from modifying the hospitals’ reimbursements with budget neutrality adjustments from years prior to the base year. The district court rejected the claims. The D.C. Circuit affirmed, finding that the revisions were neither arbitrary nor manifestly contrary to the statute. View "Adirondack Med. Ctr. v. Burwell" on Justia Law

Petitioners, a group of hospitals that serve a significant number of elderly, very low-income patients, filed suit challenging the Secretary's issuance of a rule concerning the "disproportionate share percentage" calculation of supplemental payments for low-income Medicare patients. When the Secretary published reimbursement calculations for FY 2007, petitioners learned that their payments would decrease by tens of millions of dollars per year. The rule change had an enormous financial consequence on hospitals. The court held that the Secretary did not provide adequate notice and opportunity to comment before promulgating its 2004 rule, and so affirmed the portion of the district court's opinion vacating the rule. The court reversed only the portion of the district court's opinion directing the Secretary to recalculate the hospitals' reimbursements using the alternate methodology. View "Allina Health Services, et al. v. Sebelius" on Justia Law

Plaintiffs filed suit against the Secretary of Health and Human Services (HHS) and the Commissioner of the Social Security Administration (SSA) raising constitutional challenges to the Patient Protection and Affordable Care Act (ACA), Pub. L. No 111-148, 124 Stat. 119; raising statutory challenges to actions of HHS and the Commissioner relating to the implementation of the ACA and prior Medical legislation; and attacking the failure of defendants to render an "accounting" that would alter the American people to the insolvency towards which Medicare and Social Security programs were heading. On appeal, plaintiffs challenged the district court's dismissal of their claims. The court rejected plaintiffs' claims that 26 U.S.C. 5000A, which was sustained as a valid exercise of the taxing power, violated the Fifth Amendment's prohibition of the taking of private property without just compensation and violated the origination clause. The court concluded that plaintiffs' substantive attack on the Social Security Program Operations Manual System (POMS) provisions was clearly foreclosed by its decision in Hall v. Sebelius, holding that the statutory text establishing Medicare Part A precludes any option not to be entitled to benefits. The court rejected plaintiffs' second statutory claim attacking an interim final rule. Finally, the court concluded that plaintiffs failed to provide a legal argument for their claims against the Commissioner and Secretary, and therefore, the court lacked jurisdiction over plaintiffs' claim to an "accounting." Accordingly, the court affirmed the judgment of the district court. View "Assoc. Amer. Physicians, et al. v. Sebelius, et al." on Justia Law

In 2007, the Secretary revamped Medicare's Inpatient Prospective Payment System, updating the diagnostic weighting used to calculate reimbursements for hospitals treating the program's beneficiaries. Plaintiffs sought review of the Secretary's decision regarding a downward prospective adjustment for hospital-specific rate payments. The district court concluded that the statutory scheme was ambiguous and deferred to the Secretary's reasonable interpretation of the adjustment provisions. Applying Chevron deference, the court agreed with the district court's conclusion that the statutory scheme was ambiguous and unclear. Accordingly, the court affirmed the judgment of the district court. View "Adirondack Medical Center, et al. v. Sebelius" on Justia Law

Gentiva, a provider of home healthcare services, contended that the Secretary violated the Medicare statute, 42 U.S.C. 1395ddd(f)(3), by delegating to an outside contractor the authority to determine whether Gentiva's Medicare reimbursement claims exhibited a "sustained or high level of payment error." The court affirmed the district court's decision to defer, under Chevron deference, to the Secretary's reasonable interpretation of section 1395ddd(f)(3). The court also agreed with the district court that section 1395ddd(f)(3) precluded the court from reviewing the merits of the "sustained or high level of payment error" determination. Accordingly, the court affirmed the judgment in its entirety. View "Gentiva Healthcare Corp. v. Sebelius" on Justia Law