Gottlieb Memorial Hospital v. Becerra

CourtDistrict Court, District of Columbia
DecidedMarch 25, 2025
DocketCivil Action No. 2024-0116
StatusPublished

This text of Gottlieb Memorial Hospital v. Becerra (Gottlieb Memorial Hospital v. Becerra) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gottlieb Memorial Hospital v. Becerra, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

GOTTLIEB MEMORIAL HOSPITAL, et al.,

Plaintiffs, v. Civil Action No. 24-116 (JDB) ROBERT F. KENNEDY, JR., Secretary of Health and Human Services,

Defendant. 1

MEMORANDUM OPINION

It is said that those who can’t do, instead teach. But many hospitals both do (i.e., treat) and

teach. To compensate for the collateral expenses of teaching on top of treating, Medicare gives

teaching hospitals a supplemental payment known as the “indirect medical education” (“IME”)

payment.

A complicated formula calculates a hospital’s IME payment using the ratio of the hospital’s

residents to beds. The higher this ratio, the theory goes, the more teaching a hospital does—and

therefore the more expenses fall through Medicare’s cracks, necessitating a higher IME

supplement. Because beds are in the denominator of this fraction, the more beds a hospital has,

the lower its IME payment.

Until 2013, the Centers for Medicare and Medicaid Services (“CMS”) excluded beds

dedicated to labor and delivery from its IME calculations. 2 When CMS changed its regulation to

1 See Fed. R. Civ. P. 25(d). 2 CMS administers the Medicare program on behalf of the Secretary of Health and Human Services. See Univ. Med. Ctr., Inc. v. Sebelius, 856 F. Supp. 2d 66, 70 (D.D.C. 2012). The Secretary is the defendant here, and the

1 include labor and delivery beds, the plaintiff hospitals’ IME payments decreased. The hospitals

challenge that change as contrary to the Medicare statute and arbitrary and capricious. Because it

is neither, the Court denies their motion for summary judgment and grants the Secretary’s cross-

motion.

I. Legal Background

Medicare is a federal program administered by the Secretary of Health and Human Services

(“HHS”) that provides health insurance for the elderly and the disabled. Allina Health Servs. v.

Sebelius, 746 F.3d 1102, 1105 (D.C. Cir. 2014); Dist. Hosp. Partners, L.P. v. Burwell, 786 F.3d 46,

49 (D.C. Cir. 2015). At issue in this case is Medicare’s reimbursement to hospitals for their

inpatient services, which falls in Medicare “Part A.” See Kaweah Delta Health Care Dist. v.

Becerra, 123 F.4th 939, 945 (9th Cir. 2024). For a time, reimbursement operated retrospectively,

repaying hospitals for the “reasonable cost” of “inpatient hospital services,” where the reasonable

cost equaled costs “actually incurred” less those deemed “unnecessary.” Rhode Island Hosp. v.

Leavitt, 548 F.3d 29, 39 (1st Cir. 2008). Because this approach accounted for a hospital’s actual

costs, “the reasonable cost system automatically reimbursed teaching hospitals for IME costs

related to their teaching programs.” Id.

Still, the system failed to capture the full measure of costs associated with teaching while

treating. The reasonable cost system featured per diem caps that sometimes shortchanged teaching

hospitals. See Rhode Island Hosp., 548 F.3d at 39. So, “[t]o prevent a disproportionate number

of teaching hospitals from being adversely affected,” the Secretary (by regulation) raised those

caps for teaching hospitals and pegged a hospital’s cap adjustment to a function of “the ratio of its

full-time equivalent (FTE) interns and residents . . . to its number of beds.” 45 Fed. Reg. 21582,

Court often discusses him as acting on behalf of the program. But where it is clearer to refer to “Medicare” or “CMS” instead, the Court does so. Nothing hinges on these labels. See id. at 70 n.1.

2 21584 (Apr. 1, 1980). 3 The basic idea is that the higher the ratio of trainees to beds (and therefore

to trained doctors), “the more teaching the hospital will be doing.” Little Co. of Mary Hosp. &

Health Care Ctrs. v. Shalala, 165 F.3d 1162, 1164 (7th Cir. 1999). So as that ratio increases, so

does a hospital’s IME payment. Id.

Congress overhauled Medicare in 1983 and, as relevant to this case, shifted from

retrospective to prospective assessment of the costs of inpatient care. See Social Security

Amendments of 1983, Pub. L. No. 98-21, § 601, 97 Stat. 65, 149 (1983); Dist. Hosp. Partners, 786

F.3d at 49. So now Medicare reimburses hospitals for inpatient care through the Inpatient

Prospective Payment System (“IPPS”), see 42 U.S.C. § 1395ww(a), (d), which “pays hospitals a

fixed amount for each patient” based on that patient’s expected cost of care, “regardless of the

actual costs incurred,” Grant Med. Ctr. v. Hargan, 875 F.3d 701, 703 (D.C. Cir. 2017); see 42 C.F.R.

§ 412.2(a).

In making this shift, Congress recognized that a prospective payment system threatened

teaching hospitals’ bottom line. Because the prospective system blinds itself to actual costs in

favor of expected costs based on a patient’s diagnosis, the system had no hope of accounting for

the costs associated with training new physicians while treating patients. This time, Congress

headed that concern off at the pass, “statutorily adopt[ing] the IME adjustment” that “the Secretary

created years earlier.” Rhode Island Hosp., 548 F.3d at 39–40; see also Univ. of Chi. Med. Ctr. v.

Sebelius, 618 F.3d 739, 741 (7th Cir. 2010). Congress instructed the Secretary to implement a

similar adjustment to the per diem adjustment the Secretary had devised: “The Secretary shall

provide for an additional payment amount for . . . hospitals with indirect costs of medical

3 The concept of “full-time equivalent interns and residents” has come to be a fixture in the regulatory and statutory scheme in this area, and so it will pop up numerous times in this opinion. Unfortunately, it is a mouthful. In the interests of brevity and acronym avoidance, the Court will (except when quoting) use “residents” as a shorthand. Nothing is meant by the truncation; in this opinion, “residents” means “full-time equivalent interns and residents.”

3 education.” 42 U.S.C. § 1395ww(d)(5)(B) (1984). The adjustment is and was “intended to

compensate teaching hospitals for added costs of [in]patient care unremunerated by the prospective

payment system.” Rhode Island Hosp., 548 F.3d at 44; see also Riverside Methodist v. Thompson,

No. C2-02-94 (JDH), 2003 WL 22658129, at *10 (S.D. Ohio July 31, 2003).

But—and importantly here—the 1983 Congress did not yet commit to paper any particular

formula for calculating the adjustment. Instead, Congress endorsed the Secretary’s previous

method of calculation, simply instructing the Secretary to “compute[]” the IME adjustment “in the

same manner as the adjustment for [IME] costs under regulations (in effect as of January 1, 1983)

under subsection (a)(2) of this section,” 42 U.S.C.

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Related

Batterton v. Francis
432 U.S. 416 (Supreme Court, 1977)
Shalala v. Guernsey Memorial Hospital
514 U.S. 87 (Supreme Court, 1995)
University of Chicago Medical Center v. Sebelius
618 F.3d 739 (Seventh Circuit, 2010)
Rhode Island Hospital v. Leavitt
548 F.3d 29 (First Circuit, 2008)
Northeast Hospital Corp. v. Sebelius
657 F.3d 1 (D.C. Circuit, 2011)
Nick Koretoff v. Tom Vilsack
707 F.3d 394 (D.C. Circuit, 2013)
County of Los Angeles v. Leavitt
521 F.3d 1073 (Ninth Circuit, 2008)
Northeast Hospital Corp. v. Sebelius
699 F. Supp. 2d 81 (District of Columbia, 2010)
Henry Ford Health System v. Sebelius
680 F. Supp. 2d 799 (E.D. Michigan, 2009)
Allina Health Services v. Kathleen Sebelius
746 F.3d 1102 (D.C. Circuit, 2014)
University Medical Center, Inc. v. Sebelius
856 F. Supp. 2d 66 (District of Columbia, 2012)

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