Prost, Chief Judge.
Plaintiffs-Appellants Prime Hospitals1 appeal from the order of the United States District Court for the Central District of California transferring their complaint under 28 U.S.C. § 1631 to the United States Court of Federal Claims. Prime Hospitals are seeking monetary relief for a breach of an alleged settlement agreement and, in the alternative, declaratory, injunctive, and mandamus relief from an alleged secret and illegal policy to prevent and delay Prime Hospitals from exhausting their administrative remedies.
Because Prime Hospitals’ breach of contract claim is fundamentally a suit to enforce a contract and it does not arise under the Medicare Act, we hold that the Court of Federal Claims has exclusive jurisdiction over that claim under the Tucker Act, 28 U.S.C. § 1491. We- also- hold that the Court of Federal Claims does not have jurisdiction, however, over Prime Hospitals’ alternative claims seeking declaratory, injunctive, and mandamus relief. Accordingly, we affirm the district court’s transfer order in-part, reverse-in-part, and remand for further proceedings.
Background
I
The Medicare program, which provides health insurance for the elderly and disabled, is administered by the United States Department of Health <& Humans Services (“HHS”) through its agency, the Center for Medicare & Medicaid Services (“CMS”). 42 U.S.C. §§ 1395 et seq. Medicare Part A covers hospital inpatient services and Medicare Part B covers outpatient services, including emergency room services for patients who do not require a hospital admission. See id. § 1395d, k. Under both Part A and Part B, providers submit individual claims for .payment to private contractors who make an initial determination as to what payment, if any, should be made on the claim. See id. § 1395ff(a)(l)-(2). A provider dissatisfied with the initial determination can bring a challenge through an administrative appeals process provided under the Medicare Act. See id. § 1395ff(a)-(d).
[988]*988A provider may first seek a redetermi-nation by the private contractor. Id. § 1395ff(a)(3). If still dissatisfied, the provider may then seek reconsideration by an independent entity under contract with HHS. Id. § 1395ff(b)-(c), (g). If the provider is dissatisfied with the reconsideration decision, the provider may request a hearing before an administrative law judge. See id. § 1395ff(b)(l), (c)(3)(C)(ii), (d)(1). The Medicare Appeals Council, which is part of the Departmental Appeals Board within HHS, provides the final level of administrative review. Id. § 1395ff(d)(2).
A provider that obtains a final decision from the Medicare Appeals Council is entitled to judicial review of that decision. Id. §§ 405(g), 1395ff(b)(l)(A). Under § 405(g), the provider may file suit in district court, and the Act mandates that “[n]o findings of fact or decision of the [Secretary] shall be reviewed by any person, tribunal, or governmental agency except as” provided under the Act. Id. §§ 405(h), 1395Ü.
II
Prime Hospitals are sixteen acute care hospitals that are part of Prime Healthcare Services, Inc. and Prime Healthcare Foundation, a national healthcare system that owns and operates thirty-five for-profit and non-profit hospitals in ten different states. Prime Hospitals provide inpatient hospital services under Medicare Part A to patients covered under the Medicare program.
Prime Hospitals, like other Medicare providers, submit individual claims for payment to private contractors, who make initial reimbursement determinations for the inpatient hospital services provided. Prime Hospitals alleged that, although the private contractors generally processed and paid their individual claims, many of their claims for one-day inpatient stays (known as “short-stay claims”) were subsequently subject to post-payment review and denied. In response, Prime Hospitals appealed the denials of these Medicare short-stay claims through the Medicare administrative appeal process.
Prime Hospitals alleged the audits of short-stay claims were not limited to Prime Hospitals but were part of a larger initiative that resulted in a substantial increase in hospital claim denials. As a result of this increase, Prime Hospitals alleged, CMS became overwhelmed by the number of hospital appeals of inpatient claim denials. Prime Hospitals’ complaint states that these appeals caused “the number of appeals received ... to soar from 1,250 per week in January 2012 to more than 15,000 per week in December 2013. The yearly number of ... appeals more than quintupled from 59,600 appeals in 2011 to 384,151 appeals in 2013.” J.A. 33.
In an effort to reduce the backlog of hospital appeals of Medicare short-stay claim denials and ease the administrative burden for all parties, CMS began offering health care providers the opportunity to resolve their eligible appeals through settlement, In its letter announcing the offer and corresponding settlement parameters, CMS indicated that it was proposing “to make a partial payment (68 percent of the net payable amount of the denied inpatient claim) in exchange for hospitals agreeing to the dismissal of any associated appeals and accepting] the settlement as final administrative and legal resolution of the eligible claims.” J.A. 46. CMS subsequently explained in a letter to Congressman Kevin Brady that
[t]his settlement is intended to ease the administrative burden for all parties. The settlement offers an opportunity for the government to reduce the pending appeals backlog by resolving a large number of homogeneous claims in a short period of time. In addition, the [989]*989settlement offers an opportunity for hospitals to obtain payment now for rendered services, rather than waiting a considerable amount of time with the associated risk of not prevailing in the appeals process.
J.A. 166.
Prime Hospitals alleged that, under its settlement offer, CMS agreed to pay all such Medicare short-stay appeal claims if a hospital accepted the offer of partial payment on or before' October 31, 2014, by submitting (1) a spreadsheet of eligible claims to CMS by October 31, 2014, and (2) an executed copy of the CMS administrative settlement agreement. Prime Hospitals also alleged that “[s]ubject to checking the spreadsheets to ensure that the claims were eligible Short-stay Appeal Claims, CMS expressly and unconditionally agreed to execute the settlement agreement and process the eligible claims if the Prime Hospitals accepted its offer by timely submitting the spreadsheet and an executed settlement agreement.” J.A. 34.
In particular, Prime Hospitals pointed to CMS’s settlement agreement where it stated that “[u]pon receipt of an Agreement executed by the Hospital, CMS will determine whether the list of appeals furnished by the Hospital matches CMS’s records at each level of the administrative appeals process,” and, “[i]f so, CMS will execute the Agreement,” and, “[i]f not, CMS and the Hospital will use their best efforts to work together to resolve promptly any discrepancies so that a match is achieved, at which time CMS will execute the Agreement.” J.A. 56; see also J.A. 34.
Prime Hospitals alleged that, on or before October 31, 2014, they accepted CMS’s offer by each submitting a spreadsheet of their eligible Medicare short-stay appeal claims and an executed CMS administrative settlement agreement. Thus, Prime Hospitals contends that once they accepted the offer, under the terms of the settlement agreement, the agency was contractually required to pay them sixty-eight percent of the net payable amount of their 5,079 separate Medicare appeals — a total sum equaling $23,205,245 — in exchange for their agreement that the related appeals would be dismissed.
CMS ultimately refused to allow the Prime Hospitals to participate in the CMS settlement because the agency “ha[d] been made aware of one or more ongoing False Claims Act case(s) or investigation(s) involving the facilities.” J.A. 37. Prime Hospitals alleged that the settlement agreement did not authorize such an exclusion. Accordingly, Prime Hospitals alleged that CMS failed to execute the settlement agreements as required and breached the agreement by failing to pay “the agreed-upon sum of $23,205,245.” J.A. 35.
Based on these allegations, Prime Hospitals filed a complaint in the district court for breach of contract. In their complaint, Prime Hospitals specifically alleged that: (1) CMS offered them a settlement agreement; (2) Prime Hospitals signed and otherwise accepted the agreement; (3) CMS is estopped from claiming that its signature was required to form a binding contract; (4) CMS agreed to settle Prime Hospitals’ pending Medicare administrative appeals for sixty-eight percent of the net payable amounts of those denied claims in exchange for Prime Hospitals dismissing the appeals and their acceptance of the settlements as a final administrative and legal resolution of the claims; and (5) CMS breached the agreement when it failed to pay plaintiffs the agreed-upon sum ($23,-205,245).
Prime Hospitals also pleaded two other independent and alternative causes of action in their complaint. They alleged that the seven-month delay in deciding to exclude them from CMS’s settlement pro[990]*990gram and the time in which the agency had allegedly improperly stayed their short-stay appeals amounted to “a secret and illegal policy to prevent and delay [Prime Hospitals] from exhausting their administrative remedies under the Medicare appeals process with respect to their Medicare short-stay claim denials.” J.A. 41.
In Prime Hospitals’ second alternative cause of action, Prime Hospitals requested declaratory and injunctive relief from this scheme because it violated the Medicare Act and their right to procedural and substantive due process. In Prime Hospitals’ third alternative cause of action for- a writ of mandamus, Prime Hospitals requested an order compelling the Secretary to comply with the “clear, indisputable and non-discretionary duty to provide a Medicare appeals process for [Prime Hospitals] to administratively appeal denials of their Medicare, inpatient claims, within specified time frames.” J.A. 43.
The Secretary filed a motion to dismiss the complaint on various grounds, including that the district court lacked subject matter jurisdiction over the hospitals’ breach of contract claim because under the Tucker Act, 28 U.S.C. .§■ 1491, the Court of Federal Claims had exclusive jurisdiction to adjudicate this claim.
The district court issued a written order that denied the Secretary’s motion to dismiss but transferred the case to the Court of Federal Claims. According to the district court, the Court of Federal Claims has Tucker Act jurisdiction over the Prime Hospitals’ breach of contract cause of action because it involves questions of. contract formation and scope, not questions about Medicare reimbursement law. The district court also concluded that, because Prime Hospitals’ second cause of action seeking declaratory and injunctive relief and third cause of action seeking a writ of mandamus depended on the resolution of the breach of contract claim, those claims also arose under contract law.
We have jurisdiction to review the district court’s decision to transfer Prime Hospitals’ case to the Court of Federal Claims under 28 U.S.C. § 1292(d)(4)(A).
Discussion
Wé review a district court’s decision to transfer a case under the federal transfer statute, 28 U.S.C. § 1631, to the Court of Federal Claims de novo because the district' court’s underlying determination is one of jurisdiction. Acceptance Ins. Co. v. United States, 503 F.3d 1328, 1332 (Fed. Cir. 2007). It is well settled that transfer of a case to another court is only permissible. if the destination court has subject matter jurisdiction to hear the case. Souders v. S.C. Pub. Serv. Auth., 497 F.3d 1303, 1307 (Fed. Cir. 2007) (citing 28 U.S.C. § 1631; James v. Caldera, 159 F.3d 573, 582-83 (Fed. Cir. 1998)). Accordingly, our “crucial inquiry” is whether the Court of Federal Claims has subject matter jurisdiction over the claims at issue. Souders, 497 F.3d at 1307.
We first discuss whether the Court of Federal Claims has jurisdiction to adjudicate Prime Hospitals’ claim for breach of the alleged settlement agreement. This discussion includes two parts: First, although the Court of Federal Claims typically has Tucker Act jurisdiction over any express or implied contract with the United States, the settlement agreement’ at issue here arose from disputes under the Medicare Act, which has its own comprehensive administrative and judicial review scheme. We. must, determine, therefore, whether the Medicare Act preempts Tuck- ’ er Act jurisdiction over the contract claim. We conclude that it does not. Second, because the Medicare Act’s own review scheme, which places jurisdiction in the [991]*991district court, provides the sole avenue for judicial review for all claims “arising under” the Medicare Act and the Supreme Court has construed the “arising under” language broadly, we must also determine whether the contract claim arises under the Medicare Act. We conclude that-it does not. In sum, we hold that jurisdiction over the contract claim is proper in the Court of Federal Claims.
We also address the question of whether the Court of Federal Claims has subject matter jurisdiction over Prime Hospitals’ alternative claims seeking declaratory, in-junctive, and mandamus relief from the Secretary’s alleged policy to prevent and delay Prime Hospitals from exhausting their administrative remedies. We conclude that it does not. We take each issue in turn.
A
The jurisdiction of the Court of Federal Claims is set forth in the Tucker Act, 28 U.S.C. § 1491(a), which states: .
The United States Court of Federal .Claims , shall have jurisdiction to render judgment upon any claim against the United States founded either upon the Constitution, or any Act of Congress or any régulation of an executive department, or upon any express or implied contract with the United States, or for liquidated or unliquidated damages in cases not sounding in tort.
The Tucker Act, however, does not create any substantive right enforceable against the United States. United States v. Testan, 424 U.S. 392, 398, 96 S.Ct. 948, 47 L.Ed.2d 114 (1976). In order to come within the jurisdictional reach of the .Tucker Act, a plaintiff must identify a separate source of substantive law that creates the right to money damages. Fisher v. United States, 402 F.3d 1167, 1172 (Fed. Cir. 2005) (citing United States v. Mitchell (Mitchell II), 463 U.S. 206, 216-17, 103 S.Ct. 2961, 77 L.Ed.2d 580 (1983); Testan, 424 U.S. at 398, 96 S.Ct. 948).
Contract law is one such separate source of law compensable under the Tucker Act. 28 U.S.C. § 1491(a); Higbie v. United States, 778 F.3d 990, 993 (Fed. Cir. 2015), cert. denied, — U.S. ——, 136 S.Ct. 37, 193 L.Ed.2d 25 (2015). The Supreme Court has also recognized non-contractual bases of Tucker Act jurisdiction, which include those claims “founded either upon the Constitution, or any Act of Congress, or any regulation of an executive department,” 28 U.S.C. § 1491(a). Testan, 424 U.S. at 398, 96 S.Ct. 948. In order for a noil-contractual claim to be “cognizable under the Tucker Act ,.. the claimant must demonstrate that the source of substantive law he relies upon can fairly be interpreted as mandating compensation by the Federal Government for the damages sustained.” Mitchell II, 463 U.S. at 216-17, 103 S.Ct. 2961 (internal quotation marks omitted). Tucker Act jurisdiction is preempted, however, when that non-contractual source of substantive law contains its own judicial review scheme. United States v. Bormes, 568 U.S. 6, 12, 133 S.Ct. 12, 184 L.Ed.2d 317 (2012). If such a remedial scheme exists, it will establish the exclusive framework for the monetary liability Congress created under the statute. Id.
The Medicare Act is a non-contractual source of substantive law that mandates compensation to private parties by the Federal Government. See, e.g., Appalachian Reg'l Healthcare, Inc. v. United States, 999 F.2d 1573, 1577 (Fed. Cir. 1993) (observing that the Medicare Act provides a substantive .right to money damages). It also contains .its own judicial [992]*992review scheme. See Heckler v. Ringer, 466 U.S. 602, 614-15, 104 S.Ct. 2013, 80 L.Ed.2d 622 (1984) (explaining that 42 U.S.C. §§ 405(h), (g), and 1395Ü provide “the sole avenue for judicial review for all ‘claim[s] arising under’ the Medicare Act”). Accordingly, this court has held that Tucker Act jurisdiction over Medicare reimbursement claims is preempted. St. Vincent’s Med. Ctr. v. United States, 32 F.3d 548, 550 (Fed. Cir. 1994).
There is a distinction between such non-contractual claims arising under the Constitution, a statute, or a regulation and those stemming from a contract. Holmes v. United States, 657 F.3d 1303, 1313 (Fed. Cir. 2011). Any express or implied contract with the United States provides an independent substantive right, enforceable in the Court of Federal Claims under the Tucker Act. Id. When the contract at issue, however, is a settlement agreement with the United States arising from a dispute under a statute that has its own judicial review scheme, the question remains whether Tucker Act jurisdiction over that contract claim is nevertheless preempted.
We have addressed this question with respect to a number of settlement agreements arising from disputes under statutes having their own comprehensive review schemes and each time have concluded that the statute’s review scheme does not preclude Tucker Act jurisdiction over those settlement agreements. See, e.g., Cunningham v. United States, 748 F.3d 1172, 1179 (Fed. Cir. 2014) (Civil Service Reform Act); Holmes, 657 F.3d at 1312 (Title VII); Massie v. United States, 166 F.3d 1184, 1189 (Fed. Cir. 1999) (Military Claims Act). In each case, we have drawn a distinction between claims for which the statute provides the exclusive remedy and claims for breach of settlement that fall outside the comprehensive scheme, with Tucker Act jurisdiction extending to the latter. See, e.g., Holmes, 657 F.3d at 1312. This court has yet to resolve this question with respect to settlement agreements with the United States arising from reimbursement disputes under the Medicare Act. We do so today.
We begin our analysis by reviewing the relevant jurisprudence.
The Supreme Court has identified a distinction between an action on a settlement agreement and one under a law whose alleged violation gave rise to the settlement. Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 378-82, 114 S.Ct. 1673, 128 L.Ed.2d 391 (1994); see also Holmes, 657 F.3d at 1311 n.5. This court and the Court of Federal Claims have since applied this distinction to conclude that settlement agreements are within the jurisdiction of the Court of Federal Claims because they fall outside of, and must be analyzed separately from, the statutory schemes from which they arose. See, e.g., Holmes, 657 F.3d at 1311. Relevant to our analysis, the Supreme Court has observed that “[e]nforcement of the settlement agreement ... whether through award of damages or decree of specific performance, is more than just a continuation or renewal of the dismissed suit, and hence requires its own basis for jurisdiction.” Kokkonen, 511 U.S. at 378, 114 S.Ct. 1673. The Court has also noted that “the facts to be determined with regard to such alleged breaches of contract are quite separate from the facts to be determined in the principal suit” from which the settlement arose. Id. at 380, 114 S.Ct. 1673.
In Holmes, this court held that the comprehensive statutory scheme established under Title VII was not a bar to the exercise of Tucker Act jurisdiction in a suit alleging breach of a Title VII settlement agreement. 657 F.3d at 1312. We concluded that “although the [settlement a]gree-[993]*993ments arose out of Title VII litigation, [the] suit for breach of contract is just that: a suit to enforce a contract with the government.” Id. (citing Kokkonen, 511 U.S. at 378-82, 114 S.Ct. 1673). In addition to relying on Kokkonen, the Holmes court also relied on this court’s decisions in Del-Rio Drilling Programs, Inc. v. United States, 146 F.3d 1358 (Fed. Cir. 1998) and Massie v. United States, 166 F.3d 1184 (Fed. Cir. 1999). In Del-Rio Drilling, this court held that “the fact that the court may have to interpret [an] Act or make other determinations regarding principles of state and federal law in order to resolve the contract claim does not deprive the [Court of Federal Claims] of jurisdiction to decide that claim.” 146 F.3d at 1367.
Likewise, in Massie, this court addressed whether, because the Military Claims Act (MCA) provides a complete and comprehensive statutory scheme pertaining to the payment of military claims, the Court of Federal Claims has jurisdiction over an agreement to pay an MCA claim. 166 F.3d at 1187-89. We concluded that “the MCA itself does not deprive the court of jurisdiction to hear [the contract] claim” because “the MCA does not address the breach of agreements to pay MCA claims. Nor does its legislative history shed light on this issue.” Id. at 1188. This court also found it to be dispositive that “Massie ha[d] not requested review of the substantive issues of the MCA claim — the existence and extent of the government’s liability for Massie’s injuries.” Id. at 1189. Rather, the court noted, Massie “agrees with the Secretary’s decision and seeks only to enforce the express contract embodying it.” Id.
In Cunningham v. United States, this court applied the holding in Holmes to an agreement settling a dispute arising under the Civil Service Reform Act (CSRA) and concluded that the Court of Federal Claims possessed subject matter jurisdiction over the breach of contract claim for money damages. 748 F.3d 1172, 1178-79 (Fed. Cir. 2014). It was dispositive that the adjudication of the claim for monetary relief did not involve the review of a personnel action nor did it require the Claims Court to review the facts or law underlying the initial discrimination grievance. Id. at 1178-79. Further, the suit did not demand equitable relief that might require undertaking a personnel action, but rather, sought money damages to compensate for breach of the settlement agreement. Id.
Following our decisions in this line of cases, although the alleged settlement agreement with CMS arose from disputes under the Medicare Act, Prime Hospitals’ breach of contract claim for money damages against the government falls outside of the Medicare Act’s remedial scheme.2
[994]*994Prime Hospitals’ enforcement of the settlement agreement is a separate action and not a continuation of their underlying claims for Medicare reimbursement. See Kokkonen, 511 U.S. at 378, 114 S.Ct. 1673. Prime Hospitals do not suggest that their contract claim is one that they should have been required to present to the agency in the first instance through the Medicare Act’s own comprehensive review scheme. Nor does the language of the settlement agreement itself contemplate review under the Medicare Act’s administrative review scheme. It indicates that “[a]ny dispute between the Parties under this Agreement shall be resolved by a federal court of competent jurisdiction.” J.A. 57. Rather, Prime Hospitals contend the alleged settlement was brought about to end ongoing administrative disputes. They pleaded that they agreed to dismiss their appeals and accept the settlement as a final administrative and legal resolution of their claims of entitlement to Medicare benefits. In other words, Prime Hospitals’ enforcement of the settlement agreement is not a continuation or renewal of their denied claims for Medicare reimbursement.
The facts to be determined with respect to Prime Hospitals’ breach of contract suit are also separate from the facts determined in their underlying individual claims for reimbursement. See Kokkonen, 511 U.S. at 380, 114 S.Ct. 1673. The facts to be determined with regard to the breach of contract suit include whether CMS offered a settlement agreement to Prime Hospitals, whether Prime Hospitals signed and otherwise accepted the agreement, whether CMS also accepted the settlement agreement, and whether CMS breached the agreement when it failed to pay Prime Hospitals the agreed-upon sum. Contrast these with facts that were likely determined for Prime Hospitals’ individual claims for reimbursement. For example, under the Medicare Act, as part of an initial determination, the facts to be determined include whether the items and services the provider furnished are covered or otherwise reimbursable under the Medicare Act and what amounts are payable for those items and services, if any. 42 C.F.R. § 405.902.
As in Massie and Cunningham, where this court found it dispositive that the claimant had not requested review of the facts or law underlying the initial MCA or CSRA dispute, Prime Hospitals are also not disputing the underlying determinations denying their reimbursement claims. Prime Hospitals have not requested review of, for example, whether the items and services they furnished are reimbursable under the Medicare Act nor have they requested review of what amounts are payable for those items and services. Rather, as in Massie, Prime Hospitals agree with the Secretary’s decision to settle pending Medicare administrative appeals for sixty-[995]*995eight percent of the net payable amounts of eligible claims as the final administrative and legal resolution of the claims and seek only to enforce the alleged contract they have with CMS memorializing this decision. Massie, 166 F.3d at 1189. Prime Hospitals seek the benefit of the bargain they struck with CMS. Cunningham, 748 F.3d at 1177 (observing that' “[w]hen a plaintiff seeks to obtain the benefit of the bargain struck by the plaintiff and the government in an underlying settlement agreement, the plaintiff is enforcing a contract”). Finally, as in Cunningham, Prime Hospitals do not demand equitable relief through their breach of contract data that might require undertaking an action under the Medicare Act but only money damages to compensate for breach of the settlement agreement.
To the extent that Prime Hospitals argue that their contract claim cannot fall outside of the Medicare Act’s remedial scheme because determining the scope of the settlement agreement would require an application of the Medicare Act, we disagree. See Dél-Rio Drilling, 146 F.3d at 1367. Prime Hospitals are referring to the fact that the settlement agreement provides that it is intended to resolve only “eligible claims” as defined by the settlement agreement. J.A. 54. To be eligible for settlement the agreement requires, for example, that the claim must have been- denied by any entity that conducted a review on behalf of CMS and that the hospital must have timely appealed the denial of that claim. That the settlement agreement resolves only claims for reimbursement that meet the criteria of “eligible claims,” however, does not make the settlement agreement any less of a contractual undertaking by the government. Del-Rio Drilling, 146 F.3d at 1367.
Indeed, Prime • Hospitals describe- the process for determining which claims are eligible for settlement in their complaint as simply “checking the spreadsheets.” J.A. 34. The language of the settlement agreement describes this process as follows: “Upon receipt of an Agreement executed by the Hospital, CMS will determine whether the list of appeals furnished by the Hospital matches CMS’s records at each level of the administrative appeals process.” J.A 56; see also J.A. 34. Whether or not Prime Hospitals are correct that determining the scope of the contract in this manner would require an application of the Medicare Act, that the parties might have to compare spreadsheets to determine whether their records match does not remove jurisdiction from the Court of Federal Claims. As this court held in Del-Rio Drilling, the fact that the court may have to interpret an Act or make other determinations regarding principles of federal law in order to resolve the contract claim does not deprive the Court of Federal Claims of jurisdiction to decide'that claim. 146 F.3d at 1367.3
In sum, following this court’s precedent, we hold that Prime Hospitals’ claim for monetary relief against the government alleging breach of their settlement agreement with CMS is fundamentally a suit to enforce a contract and therefore within the Court of Federal Claims’ jurisdiction under the Tucker Act.
B
Having concluded that Tucker Act jurisdiction over .Prime Hospitals’ contract [996]*996claim is not preempted, we also reject, for similar reasons, Prime Hospitals’ arguments that Court of Federal Claims is precluded from reviewing their contract claim because it “arises under” the Medicare Act.
The Medicare Act’s own comprehensive administrative and judicial review scheme provides the sole avenue for judicial review for all claims “arising under” the Medicare Act. Heckler v. Ringer, 466 U.S. 602, 614-15, 104 S.Ct. 2013, 80 L.Ed.2d 622 (1984); see also St. Vincent’s, 32 F.3d at 549-50. This judicial review scheme places jurisdiction in the district courts and therefore precludes the Court of Federal Claims from reviewing reimbursement claims arising under the Medicare Act. St. Vincent’s, 32 F.3d at 550; Wilson ex rel. Estate of Wilson v. United States, 405 F.3d 1002, 1010 (Fed. Cir. 2005).
The inquiry in determining whether the Medicare Act’s review scheme bars jurisdiction over a claim is whether the claim at issue “arises under” the Act. Ringer, 466 U.S. at 615, 104 S.Ct. 2013. The Supreme Court has construed the “claim arising under” language quite broadly to include any claims in which the Medicare Act provides both the standing and the substantive basis for the presentation of the claims. Ringer, 466 U.S. at 615, 104 S.Ct. 2013 (citing Weinberger v. Salfi, 422 U.S. 749, 760-61, 95 S.Ct. 2457, 45 L.Ed.2d 522 (1975)). Under this broad test, the Court concluded that a claim arises under the Act when it is “at bottom, a claim that they should be paid for their” Medicare services. Id. at 614, 104 S.Ct. 2013. See also Do Sung Uhm v. Humana, Inc., 620 F.3d 1134, 1142-43 (9th Cir. 2010) (concluding that “where, at bottom, a plaintiff is complaining about the denial of Medicare benefits ... the claim ‘arises under’ the Medicare Act” (emphasis added)).
The Supreme Court has also held that a claim arises under the Medicare Act when it is “inextricably intertwined” with a claim for benefits. Ringer, 466 U.S. at 614-16, 104 S.Ct. 2013. In Ringer, the claim was inextricably intertwined with a claim for benefits because the relief sought was a determination that the Medicare services were reimbursable under the Act. Id. at 614, 104 S.Ct. 2013. The Third Circuit considers a claim to be inextricably intertwined “if it does not involve issues separate from the party’s claim that it is entitled to benefits and/or if those claims are not completely separate from its substantive claim to benefits.” Nichole Med. Equip. & Supply, Inc. v. TriCenturion, Inc., 694 F.3d 340, 348 (3d Cir. 2012).
The type of remedy sought is generally not dispositive of whether the claim arises under the Medicare Act. See, e.g., Ringer, 466 U.S. at 615, 104 S.Ct. 2013 (“It is of no importance that respondents here ... sought only declaratory and in-junctive relief and not an actual award of benefits as well.”). The ultimate question is whether the claim is a claim for reimbursement benefits. See, e.g., id. (concluding that although respondents sought declaratory relief, they ultimately sought an award of benefits because “[following the declaration which respondents seek from the Secretary ... only essentially ministerial details will remain before respondents would receive reimbursement”). A claim that challenges a denial of reimbursement benefits, no matter how it is styled, is a claim'for reimbursement benefits. See, e.g., id. at 614, 104 S.Ct. 2013; Do Sung Uhm, 620 F.3d at 1142-43; Midland Psychiatric Assocs., Inc. v. United States, 145 F.3d 1000, 1004 (8th Cir. 1998); Bodimetric Health Servs., Inc. v. Aetna Life & Cas., 903 F.2d 480, 487 (7th Cir. 1990).
[997]*997Against this backdrop, Prime Hospitals maintain that their breach of contract claim arises under the Medicare Act because, at bottom, they are seeking reimbursement for services they provided to the Medicare beneficiaries. We disagree.
First, the Medicare Act does not provide either the standing or the substantive basis for the presentation of Prime Hospitals’ claim. Cf. RenCare, Ltd. v. Humana Health Plan of Tex., Inc., 395 F.3d 555, 557 (5th Cir. 2004) (finding that the standing and substantive basis for claims that are based on state law, such as breach of contract claims, are clearly not provided by the Medicare Act). Their claim does not challenge the denial of benefits in each of their individual reimbursement claims. Indeed, their underlying claims must have been denied to be considered “eligible claims” under the settlement agreement. Nor do Prime Hospitals seek any declaration or determination that the services that they provided to the Medicare beneficiaries are reimbursable under the Act. They pleaded that the settlement agreement is the final administrative and legal resolution of their eligible claims, thus they seek to dismiss their claims altogether. Finally, Prime Hospitals do not challenge provisions of the Medicare Act or its regulations as having denied them benefits. Instead, they pleaded that they were denied the amount owed to them under the settlement agreement as a direct and proximate result of the Secretary’s breach of the settlement agreement.
Unlike Do Sung Uhm where the contract claim was found to arise under the-Medicare Act, in part, because the contract at issue only imposed a duty to comply with the Medicare Act itself, 620 F.3d at 1142, Prime Hospitals’ contract almost exclusively imposes duties on CMS that do not involve compliance with the Medicare Act. The relief Prime Hospitals seek is not reimbursement payments for services they provided to the Medicare beneficiaries in each of their individual claims. Rather, they seek to dismiss their claims altogether and receive, under contract principles, the benefit of the bargain they struck with CMS. The benefit Prime Hospitals seek, as CMS itself explained, is the bargained-for payment amount which they can receive immediately through the settlement agreement, “rather than waiting a considerable amount of time with the associated risk of not prevailing in the appeals process.” J.A. 166. Prime Hospitals claim that they are owed the agreed-upon “total sum” that CMS offered to pay under the settlement agreement. J.A. 54. That Prime Hospitals also call this sum in their complaint “Medicare reimbursement” does not change the fact that the damages they seek are really the bargained-for total sum under the settlement agreement. Brazos Elec. Power Co-op., Inc. v. United States, 144 F.3d 784, 787 (Fed. Cir. 1998) (“Court of Federal Claims jurisdiction cannot be circumvented by such artful pleading and, accordingly, we customarily look to the substance of the pleadings rather than their form.”).
Unlike the cases upon which Prime Hospitals rely, their alleged injury, cannot be remedied through the retroactive payment of Medicare benefits nor can it be remedied through the Act’s administrative review process. See, e.g., Do Sung Uhm, 620 F.3d at 1143-44; Bodimetric, 903 F.2d at 486. Because Prime Hospitals seek the benefit of the bargain under the settlement agreement and do not challenge the Secretary’s denial of their claims for payment for their Medicare services, they do not have an adequate remedy under the Medicare review scheme. Cf. Ringer, 466 U.S. at 617, 104 S.Ct. 2013 (concluding that respondents clearly had an adequate remedy in the Medicare review scheme for challenging the Secretary’s denial of their claims). See also Wilson, 405 F.3d at 1010 [998]*998n.9 (clarifying that the Medicare Act does not preclude judicial review in the Court of Federal Claims when the specialized administrative and judicial review processes provided in the statute are not available).
Second, Prime Hospitals’ breach of contract claim is not inextricably intertwined with their underlying claims for Medicare benefits. Prime Hospitals’ breach of contract claim involves' separate issues and is completely separate from a substantive claim to benefits. See Nichole Med., 694 F.3d at 348. Also, unlike the cases upon which Prime Hospitals rely, hearing their breach of contract claim will not mean reviewing the merits of the underlying reimbursement claims decisions,. See, e.g., Midland, 145 F.3d at 1004. Cf. Kaiser v. Blue Cross of Cal., 347 F.3d 1107, 1114-15 (9th Cir. 2003) (concluding that the only claims that do not arise under the Medicare Act are the defamation and invasion of privacy claim, because the alleged facts are largely independent of the underlying Medicare law).
In particular, Prime Hospitals’ breach of contract claim involves issues such as whether .CMS offered a settlement agreement to Prime Hospitals, whether Prime Hospitals and CMS both accepted the settlement agreement, and whether , CMS breached the agreement when it failed to pay Prime Hospitals the agreed-upon sum. These issues are separate from those that would arise in a substantive claim of entitlement to benefits, such as, whether the items and services Prime Hospitals furnished are covered or otherwise reimbursable . under- -the Medicare .Act and what amounts are payable .for those items and services, if any. 42 C.F.R. § 405.902. Importantly, Prime Hospitals do not challenge any such findings as they do not challenge the denials of their underlying individual reimbursement claims. Rather, Prime,. Hospitals have alleged that their claims of entitlement to Medicare benefits are, fully resolved, both administratively and legally, by the settlement agreement, and they seek payment only under the alleged contract.
In support of their argument that then-breach of contract claim arises under the Medicare Act, Prime Hospitals centrally rely on Pines Residential Treatment Center, Inc. v. United States, 444 F.3d 1379 (Fed. Cir. 2006). This case, however, is readily distinguishable.
Pines Residential, an operator of a hospital, entered into a written settlement agreement -with a Medicare Intermediary who agreed to allow a loss of an agreed-upon amount and issue a revised notice of program reimbursement reflecting this allowance. Id. at 1380. The Intermediary then complied with the settlement agreement and issued revised notices reflecting the agreed-upon loss and stating that a check-would be issued if payment were due. Id. Before the Court of Federal Claims, the government provided evidence showing that Pines Residential did not receive any payment because the Intermediary had offset the: agreed-upon loss amount against an overpayment. Brief for Defendant-Appellee at 11, Pines Residential Treatment Ctr., 444 F.3d 1379 (Fed. Cir. Aug. 31, 2005) (No. 05-5102), 2005 WL 2477446 at *11. Thus, the only issue -that could be litigated, the government argued, was whether the offset decision was proper and appropriate according to the Medicare statutes. and .regulations. Id. at *35. This court affirmed the .Court of Claims’ finding that it was without jurisdiction to hear Pines Residential’s claim because, although styled as a breach of contract claim, it was, at a minimum, inextricably intertwined with a claim for Medicare reimbursement. Pines, 444 F.3d at 1381. Determining whether the-<offset claimed by the govern[999]*999ment was proper would require application of the provisions of the Medicare Act. Id.
Unlike Pines Residential’s settlement agreement, which did not entitle it to payment, here, Prime Hospitals’ alleged settlement agreement entitles them to a total sum in exchange for dismissing their eligible reimbursement appeals. Also unlike Pines where the parties disagreed as to whether the payment owed was properly applied to an overpayment under the applicable Medicare regulations, here, Prime Hospitals and the government only dispute whether or not a contract was formed between Prime Hospitals and CMS. They do not disagree as to, or even discuss, the merits of Prime Hospitals’ individual reimbursement’ claims from which the alleged settlement agreement arose. Thus, unlike Pines, where determining whether any payment was due to Pines Residential would almost exclusively require resolving questions under the Medicare Act, here determining whether Prime Hospitals are entitled to the total sum payment in exchange for dismissing their eligible reimbursement appeals requires an analysis of whéther a contract was formed under contract principles.
In sum, Prime Hospitals’ breach of contract claim does not arise under the Medicare Act because they do not seek reimbursement for services provided to Medicare beneficiaries. It is contract law, and not the Medicare Act, that provides both the standing and the substantive basis for the presentation of Prime Hospitals’ breach of contract claim. Also, Prime Hospitals’ enforcement of their settlement agreement is not inextricably intertwined with their underlying claims for Medicare benefits because their claim involves separate issues and is completely separate from a substantive claim that they are entitled to benefits.
Prime Hospitals’ breach of contract claim is just that: a. suit to enforce a contract with the government, and it does not arise under the Medicare Act.
We turn now to Prime Hospitals’ remaining claims for declaratory, injunctive, and mandamus relief. Prime Hospitals and the government' do not dispute that the Court of Federal Claims does not have jurisdiction to adjudicate these claims. Indeed, the government had not asked the district court to transfer these claims but had sought dismissal on other grounds. We conclude that the Court of Federal Claims lacks jurisdiction over Prime Hospitals’ remaining claims.
The Tucker Act does not generally confer jurisdiction for actions seeking declaratory or injunctive relief. See Richardson v. Morris, 409 U.S. 464, 465, 93 S.Ct. 629, 34 L.Ed.2d 647 (1973). Although, as the government identifies, there are a limited number of statutory exceptions to that rule, none are applicable here. Similarly, the Court of Federal Claims does not have jurisdiction to issue a writ of mandamus pursuant to 28 U.S.C. § 1361. See Hornback v. United States, 405 F.3d 999, 1002 (Fed. Cir. 2005) (“28 U.S.C. § 1361 vests ‘original jurisdiction’ for the issuance of mandamus orders in the district courts.”).
Accordingly, we conclude that the Court of Federal Claims does not have jurisdiction over Prime Hospitals’ remaining claims and we reverse the district court’s order transferring Prime Hospitals’ claims for declaratory, injunctive, and mandamus relief. Cf. United States v. Cty. of Cook, Ill., 170 F.3d 1084, 1089 (Fed. Cir. 1999) (“Section 1631 allows for the transfer of less than all of the claims in a civil action to the Court of Federal Claims.”).
[1000]*1000Conclusion
For the foregoing reasons, we hold that the Court of Federal Claims has exclusive jurisdiction under the Tucker Act, 28 U.S.C. § 1491, over Prime Hospitals’ breach of contract claim but does not have jurisdiction over their remaining claims. Accordingly, we affirm the district court’s transfer order with respect to the breach of contract claim but reverse with respect to Prime Hospitals’ remaining claims seeking declaratory, injunctive, and mandamus relief. We remand for further proceedings.
AFFIRMED IN PART, REVERSED IN PART, AND REMANDED
Costs
The parties shall bear their own costs.
Dissenting opinion filed by Circuit Judge NEWMAN.