Hmh Hospitals Corporation v. Becerra

CourtDistrict Court, District of Columbia
DecidedOctober 9, 2025
DocketCivil Action No. 2024-1901
StatusPublished

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

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,

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

1 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

2 (“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

3 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.

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

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)

Cite This Page — Counsel Stack

Bluebook (online)
Hmh Hospitals Corporation v. Becerra, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hmh-hospitals-corporation-v-becerra-dcd-2025.