Johnson v. Becerra

CourtDistrict Court, District of Columbia
DecidedApril 5, 2023
DocketCivil Action No. 2022-3024
StatusPublished

This text of Johnson v. Becerra (Johnson 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
Johnson v. Becerra, (D.D.C. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

CATHERINE JOHNSON, et al.,

Plaintiffs,

v. Case No. 1:22-cv-03024 (TNM)

XAVIER BECERRA, in his official capacity as Secretary of Health and Human Services,

Defendant.

MEMORANDUM OPINION

Medicare beneficiaries with chronic, debilitating conditions have struggled to find home

health agencies (HHAs) willing or able to provide them with in-home aide services. They now

sue the Secretary of Health and Human Services (HHS) for his role in administering the

Medicare program. Plaintiffs allege that an assortment of the Secretary’s policies and practices

deter the availability of aide services in violation of the Medicare statute and the Rehabilitation

Act.

The Secretary moves to dismiss for lack of subject matter jurisdiction and alternatively

for failure to state a claim. Because Plaintiffs lack standing to challenge the Secretary’s policies,

the Court lacks subject matter jurisdiction and must grant the Secretary’s motion.

I.

A.

Medicare reimburses private agencies that care for eligible aged and disabled persons.

The Centers for Medicare & Medicaid Services (CMS), a component of HHS, administers this

health insurance program. Medicare covers some services that are provided in the home by

participating home health agencies. These services include skilled nursing services, physical and occupational therapy, and, relevant here, “part-time or intermittent services of a home health

aide.” 42 U.S.C. § 1395x(m)(1), (2), (4).

Home health aides “provide hands-on personal care to the beneficiary, or services that are

needed to maintain the beneficiary’s health, or [] facilitate treatment of the beneficiary’s illness

or injury.” Compl. ¶ 43; see also C.F.R. § 409.45(b)(1). An aide might, for example, assist a

beneficiary with bathing, dressing, or moving around his home. See Compl. ¶ 44. Aides may

also provide incidental services, such as changing bed linens, personal laundry, or preparing a

light meal. See Compl. ¶ 45; see also C.F.R. § 409.45(b)(4). Medicare covers up to 28 hours

(or, in some cases, up to 35 hours) of aide services per week. See 42 U.S.C. § 1395x(m).

If a beneficiary is eligible and referred to home health services, the beneficiary identifies

an HHA in his area that is willing and able to accept him as a patient. To help patients decide

which HHA is right for them, the Medicare statute requires the Secretary to collect care quality

data from HHAs and share that data with the public. See 42 U.S.C. § 1395fff(b)(3)(B)(v); 42

C.F.R. § 484.245. To do so, the Secretary publishes a consumer-facing metric known as the

“Quality of Patient Care Star Ratings.” See generally Fact Sheet: Quality of Patient Care Star

Rating, CMS, https://perma.cc/53Z6-LVKK. This web-based system assigns each HHA a rating

ranging from one to five stars, with five stars indicating highest quality. See id. at 1. The Star

Ratings are determined using a formula based on “seven measurements of quality.” Id. Five

track patient improvement, such as improvement in mobility or breathing. See id.

All HHAs reserve the right to choose which patients they serve. And an HHA need not

accept Medicare at all. See 42 U.S.C. § 1395a(a) (providing that a beneficiary may obtain health

services “if such institution, agency, or person undertakes to provide him such services”

(emphasis added)). More, an HHA may only accept a patient when it reasonably expects that it

2 can meet the patient’s needs and provide the services described in her plan of care. See 42

C.F.R. § 484.60(a)(1) (“Patients are accepted for treatment on the reasonable expectation that an

HHA can meet the patient’s medical, nursing, rehabilitative, and social needs in his or her place

of residency.”). And once an HHA has accepted a patient, it must provide care as described in

the patient’s plan of care. See id. § 484.60 (“Each patient must receive the home health services

that are written in an individualized plan of care . . . .”).

Medicare imposes other conditions of participation on HHAs. For example, an HHA is

required to “arrange a safe and appropriate transfer to other care entities” if it discharges a

patient. Id. § 484.50(d)(1). It must also accept, document, and investigate patient complaints.

See id. § 484.50(e)(1). If CMS receives many complaints, it must survey the HHA for

compliance. See 42 U.S.C. § 1395bbb(c)(2)(B)(ii). CMS must also conduct a standard survey of

every HHA no less than once every three years. See id. § 1395bbb(c)(2)(A). And HHAs must

meet all applicable civil rights requirements, including Section 504 of the Rehabilitation Act of

1973. See 42 C.F.R. § 489.10.

Under the Medicare statute, the Secretary has the “duty and responsibility” to “assure”

that “the enforcement of such conditions and requirements are adequate to protect the health and

safety of individuals under the care of a[n] [HHA] and to promote the effective and efficient use

of public moneys.” Id. § 1395bbb(b). CMS has the concomitant responsibility to terminate

agreements with HHAs that fail to comply with the conditions and requirements of participation.

See 42 C.F.R. §§ 489.53(a)(9), 489.2(b)(3).

Because these services are not provided directly by the federal government, Medicare

reimburses participating HHAs when they provide covered services. To control costs, Medicare

pays HHAs prospectively for their services rather than reimbursing providers after-the-fact. This

3 is required by statute. See 42 U.S.C. § 1395fff(a). Medicare reimbursements are based on 30-

day periods of home health care. See id. § 1395fff(b)(2)(B). To calculate payments, each period

is categorized into one of 432 “case-mix” groups based on the beneficiary’s specific care

requirements. See 42 C.F.R. § 484.202. For instance, Medicare pays a higher rate for treatment

of patients with certain comorbidities or for patients in a clinical grouping that has historically

required more intensive care. The Secretary annually updates payment rates and policies through

administrative rulemaking. See Compl. ¶ 58.

B.

Now to the substance of this case. The individual Plaintiffs in this putative class action

are Medicare beneficiaries with chronic, disabling conditions. See Compl. ¶¶ 15–17. Though

Medicare covers their aide services, they have struggled to find providers willing or able to

provide those services. At times, Plaintiffs have found HHAs to accept them as Medicare

patients. Even then, they were not provided with the full amount or duration of aide described in

their plans of care.

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