Hmh Hospitals Corporation v. Becerra

District Court, District of Columbia·Decided October 9, 2025·No. Civil Action No. 2024-1901·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

HMH HOSPITALS CORPORATION, dba HACKENSACK UNIVERSITY MEDICAL CENTER, et al., Plaintiffs, Civil Action No. 24-1901 (BAH)

v. Judge Beryl A. Howell

ROBERT F. KENNEDY, JR., in his official capacity as Secretary of Health and Human Services,

Defendant.

HMH HOSPITALS CORPORATION, dba HACKENSACK UNIVERSITY MEDICAL CENTER, et al., Civil Action No. 24-cv-3261 (BAH)

Plaintiffs,

Judge Beryl A. Howell

v.

ROBERT F. KENNEDY, JR., in his official capacity as Secretary of Health and Human Services,

Defendant.

MEMORANDUM OPINION

The Medicare Act, see 42 U.S.C. §§ 1395 et seq., sets forth a “reticulated statutory scheme” that imposes stringent administrative channeling and exhaustion requirements. Bowen v. Michigan Acad. of Fam. Physicians, 476 U.S. 667, 667 (1986). In this consolidated action, a small group of hospitals filed two suits against defendant, the Secretary of Health and Human Services (“HHS”) in his official capacity, alleging that defendant’s calculation of their supplemental security income (“SSI”) fractions for Fiscal Year (“FY”) 2015 and FY 2016

resulted in underpayments by Medicare’s reimbursement program. See HMH Hospitals Corp., et al. v. Becerra, No. 24-cv-1901 (D.D.C.) (“HMH I”) (challenging FY 2016 calculations); HMH Hospitals Corp., et al. v. Becerra, No. 24-cv-3261 (D.D.C.) (“HMH II”) (challenging FY 2015 calculations).

In the first of these consolidated actions, HMH I, plaintiffs concede that they have not received a final decision in their administrative appeal pending before the Provider Reimbursement Review Board (“the Board”). See HMH I Compl. ¶ 79. In the second of these consolidated actions, HMH II, plaintiffs twice asked the Board to allow them to seek judicial review before receiving a final Board decision, a mechanism under the Medicare statute known as expedited judicial review (“EJR”), but the Board denied plaintiffs’ requests on procedural and factual grounds. Despite receiving neither a final decision from the Board nor permission to seek EJR, plaintiffs filed two suits in federal court and challenged the reimbursement determinations for FY 2015 (in HMH II) and FY 2016 (in HMH I). Defendant moved to dismiss the case for lack of subject matter jurisdiction and failure to state a claim, and both sides cross-moved for summary judgment.

This Court lacks subject matter jurisdiction over plaintiffs’ substantive claims challenging their SSI fraction reimbursements in FY 2015 and FY 2016, due to plaintiffs’ failure to exhaust their administrative remedies, which failure is not excused by futility. Though plaintiffs sought EJR for their FY 2015 SSI fraction reimbursement challenge, the Board’s denial is not a “final decision” subject to judicial review. See 42 U.S.C. § 405(g). Nor is plaintiffs’ request for mandamus relief to obtain certain data from HHS supported by a clear right to relief or defendant’s duty to act. Accordingly, plaintiffs’ Complaints seeking relief, under the Medicare Act, 42 U.S.C. §§ 405(g), 1395oo(f)(1), and the Administrative Procedure Act

(“APA”), 5 U.S.C. § 706(2), see HMH II Compl. ¶¶ 77-80 (Count 1), ECF No. 1, HMH I Am. Compl. ¶¶ 79-94 (Count 1), ECF No. 16, are dismissed for lack of subject matter jurisdiction, and their requests for relief, under the Mandamus Act, 28 U.S.C. § 1361, see HMH II Compl. ¶¶ 81-86 (Count 2), HMH I Am. Compl. ¶¶ 95-100 (Count 2), are dismissed for failure to state a claim. The parties’ respective motions for summary judgment are denied as moot. I. BACKGROUND “Resolving the instant motions requires navigating the ‘labyrinthine world’ of Medicare reimbursements.” Ascension Borgess Hosp. v. Becerra, 557 F. Supp. 3d 122, 124 (D.D.C. 2021) (BAH), aff’d, 61 F.4th 999 (D.C. Cir. 2023) (quoting Adirondack Med. Ctr. v. Sebelius, 740 F.3d 692, 694 (D.C. Cir. 2014)). To aid understanding, the following sections describe the Medicare Act’s administrative and judicial review scheme, the key statutory and regulatory provisions, and the factual and procedural background underlying the challenged agency actions.

A. Statutory and Regulatory Framework 1. Review of Medicare Reimbursement Determinations The Medicare Act, enacted in 1965 as Title XVIII of the Social Security Act, established a federal program that provides health insurance for the elderly and disabled. See Social Security Amendments of 1965, Pub. L. No. 89-97, 79 Stat. 286 (codified as amended at 42 U.S.C. §§ 1395 et seq.). In establishing Medicare, “Congress enacted a ‘reticulated statutory scheme’ ‘detail[ing] the forum and limits of review’ of all claims for Medicare benefits.” Row 1 Inc. v. Becerra, 92 F.4th 1138, 1140 (D.C. Cir. 2024) (quoting Michigan Acad. of Fam. Physicians, 476 U.S. at 675). Generally, any challenges to a Medicare reimbursement decision must “first be raised and exhausted” before the agency pursuant to the “‘special review system’ specifically designed for Medicare claims.” Id. at 1142 (quoting Shalala v. Illinois Council on Long Term Care, Inc., 529 U.S. 1, 8 (2000)). The purpose of administrative presentment and exhaustion is

to “assure[] the [Secretary] greater opportunity to apply, interpret, or revise policies, regulations, or statutes without possibly premature interference by different individual courts.” Illinois Council, 529 U.S. at 13. To that end, Section 405(h) of the Medicare Act strips courts of all jurisdiction to review decisions of the Secretary “except as [t]herein provided” by Section 405(g) of the Medicare Act. 42 U.S.C. § 405(h); see also Illinois Council, 529 U.S. at 10 (“Section 405(h) purports to make exclusive the judicial review method set forth in § 405(g).”). Under Section 405(g), a party may obtain judicial review only after a “final decision of the [Secretary] made after a hearing to which he was a party.” 42 U.S.C. § 405(g).

The Medicare program is administered by the Centers for Medicare and Medicaid Services (“CMS”) on behalf of the Secretary. 42 U.S.C. § 1395kk(a). CMS in turn contracts with intermediaries known as Medicare administrative contractors—often insurance companies—who help with processing claims and administering benefits. See Battle Creek Health Sys. v. Kennedy, No. 23-5310, 2025 WL 2423686, at *2 (D.C. Cir. Aug. 22, 2025); see also 42 U.S.C. § 1395kk-1. A provider dissatisfied with an adverse Medicare reimbursement decision that also satisfies a statutory amount-in-controversy requirement may appeal the Medicare contractor’s decision to the Board, an administrative body appointed by the Secretary. See 42 U.S.C. § 1395oo(a)(1)(A)(i), (2)-(3), (d) & (h). The Board decision “shall be final unless the Secretary, on his own motion, and within 60 days after the provider of services is notified of the Board’s decision, reverses, affirms, or modifies the Board’s decision.” 42 U.S.C. § 1395oo(f)(1); see also 42 C.F.R. § 405.1875 (reflecting that the Secretary has delegated his authority to reverse, affirm, or modify to the Administrator of CMS). “[W]ithin 60 days of the date on which notice of any final decision by the Board or of any reversal, affirmance, or modification by the Secretary is received,” providers “shall have the right to obtain judicial

review of any final decision of the Board, or of any reversal, affirmance, or modification by the Secretary, by a civil action commenced [in federal district court].” 42 U.S.C. § 1395oo(f)(1).

Free access — add to your briefcase to read the full text and ask questions with AI

Hmh Hospitals Corporation v. Becerra, (D.D.C. 2025).

Hmh Hospitals Corporation v. Becerra (Hmh Hospitals Corporation v. Becerra) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Wilbur v. United States Ex Rel. Kadrie
281 U.S. 206 (Supreme Court, 1930)
Schweiker v. Wilson
450 U.S. 221 (Supreme Court, 1981)
Block v. Community Nutrition Institute
467 U.S. 340 (Supreme Court, 1984)
Bowen v. Michigan Academy of Family Physicians
476 U.S. 667 (Supreme Court, 1986)
Bethesda Hospital Assn. v. Bowen
485 U.S. 399 (Supreme Court, 1988)
Bennett v. Spear
520 U.S. 154 (Supreme Court, 1997)
Arbaugh v. Y & H Corp.
546 U.S. 500 (Supreme Court, 2006)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Maxwell, Lawrence v. Snow, John
409 F.3d 354 (D.C. Circuit, 2005)
In Re Medicare Reimbursement Litigation
414 F.3d 7 (D.C. Circuit, 2005)
Sebelius v. Auburn Regional Medical Center
133 S. Ct. 817 (Supreme Court, 2013)