Ashli Healthcare, Inc. v. Kennedy

CourtDistrict Court, E.D. California
DecidedApril 16, 2025
Docket1:23-cv-01443
StatusUnknown

This text of Ashli Healthcare, Inc. v. Kennedy (Ashli Healthcare, Inc. v. Kennedy) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ashli Healthcare, Inc. v. Kennedy, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 ----oo0oo---- 11 12 ASHLI HEALTHCARE, INC., No. 1:23-cv-1443 WBS BAM 13 Plaintiff, 14 v. MEMORANDUM AND ORDER RE: MOTIONS FOR SUMMARY JUDGMENT 15 ROBERT F. KENNEDY, JR.,1 in his official capacity as Secretary, 16 United States Department of Health and Human Services, 17 Defendant. 18 19 ----oo0oo---- 20 Plaintiff Ashli Healthcare, Inc. (“Ashli” or 21 “plaintiff”) brought this action seeking judicial review of the 22 final decision of the United States Department of Health and 23 Human Services (“defendant” or “Secretary”). (First Amended 24 Compl. (“FAC”) (Docket No. 23).) Both parties have moved for 25 summary judgment. (Docket Nos. 39-40.) The court held hearings 26 1 Pursuant to Federal Rule of Civil Procedure 25(d), 27 Secretary of Health and Human Services Robert F. Kennedy, Jr., has been substituted for former Secretary of Health and Human 28 Services Xavier Becerra. (Docket No. 56.) 1 on the motions on January 21 and February 20, 2025. 2 I. Medicare Payment and Review 3 “Medicare is a federally funded program that reimburses 4 healthcare providers for delivering medical care to qualifying 5 elderly and disabled individuals.” New LifeCare Hosps. of N.C., 6 LLC v. Becerra, 7 F.4th 1215, 1219 (D.C. Cir. 2021). The 7 Department of Health & Human Services (“HHS”) administers 8 Medicare via the Centers for Medicare and Medicaid Services 9 (“CMS”). Id. The federal government spends about “half a 10 trillion dollars” per year on Medicare.2 Palm Valley Healthcare 11 v. Azar, 947 F.3d 321, 323-24 (5th Cir. 2020). This is in part 12 due to providers and beneficiaries filing “over 1 billion claims” 13 with Medicare every year. MedEnvios Healthcare, Inc. v. Becerra, 14 725 F. Supp. 3d 1343, 1348-50 (S.D. Fla. 2024), reconsideration 15 denied, No. 23-20068-Civ, 2024 WL 3251329, at *2-3 (S.D. Fla. 16 July 1, 2024).3 17 Medicare pays about 98% of these claims with minimal 18 review. United States v. Bergman, 852 F.3d 1046, 1054 (11th Cir. 19 2017); Gulfcoast Med. Supply, Inc. v. Sec’y, Dep’t of Health & 20 Human Servs., 468 F.3d 1347, 1349 (11th Cir. 2006). A provider 21

22 2 The court uses the term “Medicare” to refer collectively to the various government agencies and contractors 23 involved with administering the Medicare program, including the Department of Health and Human Services, the Centers for Medicare 24 and Medicaid Services, and the various contractors involved in processing, reviewing, paying, and auditing claims and appeals. 25

26 3 Because of the similarities between this action and the MedEnvios action in the Southern District of Florida (which 27 involves the same counsel for plaintiff in this action and many of the same claims), the court will refer to the multiple 28 decisions issued by the court in MedEnvios in this opinion. 1 or supplier dissatisfied with Medicare’s resolution of a 2 particular claim may appeal the decision through an 3 administrative appeals process, and then, after exhausting the 4 administrative process, may seek review by a federal district 5 court. Gulfcoast, 468 F.3d at 1349 (citing 42 U.S.C. § 405, 6 1395ff(b)(1)(A); 42 C.F.R. § 405.801). A provider or supplier 7 has 120 days to appeal Medicare’s initial decision as to a 8 particular claim, and one year to “reopen” a claim to provide new 9 evidence and get a new determination. 42 C.F.R. §§ 405.942(a), 10 405.980(c). 11 Because prepayment review of all of the over 1 billion 12 annual Medicare claims would be unfeasible, Medicare relies in 13 part on post-payment audits to ensure the claims are medically 14 necessary and meet the requirements of the Medicare program. 15 MedEnvios, 725 F. Supp. 3d at 1346. To review Medicare claims, 16 Congress created the Medicare Integrity Program, through which 17 Medicare contracts with private entities “for the purpose of 18 identifying underpayments and overpayments, and recouping 19 overpayments.” 42 U.S.C. §§ 1395ddd(a), (h)(1). When Medicare 20 determines via these audits that a provider or supplier has been 21 overpaid for its claims, it may assess an “overpayment” against 22 it. See 42 U.S.C. § 1395ddd(b).4 In other words, Medicare 23 4 Under Medicare, a “provider of services” or “provider” 24 is “a hospital, critical access hospital, skilled nursing facility, comprehensive outpatient rehabilitation facility, home 25 health agency, hospice program, or . . . a fund.” 42 U.S.C. § 1395x(u). A “supplier” is “a physician or other practitioner, 26 a facility, or other entity (other than a provider of services) 27 that furnishes items or services” to Medicare beneficiaries. 42 U.S.C. § 1395x(d). For purposes of this order, the court uses 28 the terms provider and supplier interchangeably. 1 demands that the provider repay the amount it received in excess 2 of Medicare’s allowed reimbursement. 3 To determine overpayments, federal law authorizes 4 Medicare to investigate a sample of a provider’s Medicare claims. 5 See 42 U.S.C. § 1395ddd(f). If the audit of that sample reveals 6 “a sustained or high level of payment error,” Medicare may take 7 the sample’s overpayment rate and apply to it to a “universe,” or 8 larger number of similar claims, to extrapolate a total 9 overpayment amount. Medicare may then demand that overpayment 10 amount from the Medicare provider. See 42 U.S.C. 11 § 1395ddd(f)(3). 12 II. Ashli’s Audit and Administrative Appeals 13 Ashli is a California corporation which supplies 14 medical equipment, including ventilators and other respiratory 15 equipment, to Medicare beneficiaries. (Administrative Record 16 (“R.”) at 1615.)5 In 2022, a Medicare contractor performed an 17 audit of Ashli’s claims from November 19, 2019, and November 19, 18 2020.6 (R. at 999-1000.) The contractor took a sample of 90 19 claims out of the universe of the 5,545 claims submitted by Ashli 20 that Medicare fully or partially paid during that date range, 21 excluding the “zero-paid” claims, meaning those claims for which 22 Ashli received no payment. (Id.) The contractor determined that 23 some of those 90 claims did not meet Medicare requirements, and 24 then extrapolated the amount that plaintiff was overpaid on those

25 5 Defendant lodged the full administrative record with the court instead of filing it via the court’s electronic case 26 management system. (See Docket No. 24.) 27 6 The audit was performed by Unified Program Integrity 28 Contractor Qlarant Integrity Solutions, LLC. (R. at 999-1002.) 1 90 claims to the universe of 5,545 total claims to calculate a 2 total overpayment amount of $1,354,864.00. (R. at 3877-4150 3 (initial determinations of claims); id.

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Ashli Healthcare, Inc. v. Kennedy, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ashli-healthcare-inc-v-kennedy-caed-2025.