Mercy Hospital, Inc. v. Burwell

CourtDistrict Court, District of Columbia
DecidedJuly 25, 2016
DocketCivil Action No. 2015-1236
StatusPublished

This text of Mercy Hospital, Inc. v. Burwell (Mercy Hospital, Inc. v. Burwell) 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
Mercy Hospital, Inc. v. Burwell, (D.D.C. 2016).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

MERCY HOSPITAL, INC. Plaintiff, v. Civil Action No. 15-1236 (JDB) SYLVIA M. BURWELL, Secretary, United States Department of Health and Human Services, Defendant.

MEMORANDUM OPINION

Plaintiff Mercy Hospital operates an inpatient rehabilitation facility that is eligible for

reimbursement under Medicare. The Hospital believed that the Medicare contractor responsible

for determining the reimbursement amounts applied the wrong formula for the years 2002, 2003,

and 2004, so it filed an administrative appeal. The Provider Reimbursement Review Board agreed

with the Hospital. But the Administrator of the Centers for Medicare and Medicaid Services

reversed the Board’s decision, concluding that a statutory provision precluded administrative or

judicial review of the contractor’s reimbursement determination. The Hospital now seeks judicial

review of that decision. The Hospital argues that the Administrator has read the statutory provision

too broadly, and that the type of error alleged here is not shielded from review. The Court

concludes, however, that the plain language of the statute precludes review of the contractor’s

determination. The case will therefore be dismissed.

BACKGROUND

Under Medicare, inpatient rehabilitation facilities are reimbursed pursuant to a prospective

payment system. In this context, “prospective” does not mean that a facility is paid in advance,

but rather that its reimbursement is based on payment rates fixed in advance, and not on the

1 facility’s actual costs. See Washington Hosp. Ctr. v. Bowen, 795 F.2d 139, 142 n.2 (D.C. Cir.

1986) (discussing the analogous prospective payment system for acute care hospitals). The

statutory foundation of the prospective payment system for inpatient rehabilitation facilities is

found at 42 U.S.C. § 1395ww(j). (While the Court will do its best to summarize the relevant

features of § 1395ww(j), the reader will benefit from having a copy of the provision at hand.)

Subparagraph (3)(A) instructs the Secretary of the Department of Health and Human

Services (HHS) to “determine a prospective payment rate for each payment unit for which [a]

rehabilitation facility is entitled to receive payment under this subchapter.” A “payment unit”

refers to a discharge, § 1395ww(j)(1)(D), meaning that the Secretary must determine a rate

applicable to each discharged patient. The Secretary begins by estimating “the average payment

per payment unit . . . for inpatient operating and capital costs of rehabilitation facilities using the

most recent data available,” § 1395ww(j)(3)(A); in other words, she estimates the costs associated

with the average inpatient rehabilitation patient. That average amount is then adjusted for five

factors listed in clauses (i) through (v) of subparagraph (3)(A). First, it is increased for inflation

by a factor based on price increases in a relevant market basket of goods and services. Second, it

is reduced somewhat as a counterbalance or offset for additional payments made in certain

unusually high-cost “outlier” cases. Third, it is adjusted to reflect variations in local labor costs

(the “area wage adjustment”). Fourth, it is adjusted by a “weighting factor” that depends on the

costs associated with the category of case—the “case mix group,” in the statute’s terminology—

into which the patient falls (e.g., spinal injury, stroke, amputation, etc.). Finally, it is adjusted “by

such other factors as the Secretary determines are necessary to properly reflect variations in

necessary costs of treatment among rehabilitation facilities.”

2 Note a feature of subsection (j) that will later become important: Although the instructions

to apply these five adjustments are located within paragraph (3), the details of some of the

adjustments are located in other paragraphs. For example, clause (3)(A)(iv) instructs the Secretary

to apply the weighting factor adjustment, but it is paragraph (2) that actually tells the Secretary to

establish the case mix groups and to assign a weighting factor to each. Similarly, clause (3)(A)(iii)

instructs the Secretary to apply the area wage adjustment, but the parameters of that adjustment

are explained in paragraph (6). This is not true, however, of the final, “other factors” adjustment

in clause (3)(A)(v). Because that clause is an authorization for the Secretary to develop other

adjustments through the administrative process, there is no cross-reference to other portions of the

statute.

This case concerns one such “other factors” adjustment that the Secretary has authority to

develop under clause (v): the Low-Income Percentage (LIP) adjustment. The LIP adjustment is

designed to increase the payment rate at facilities that serve a significant number of low-income

patients, “because as a facility’s percentage of low-income patients increases, there is an

incremental increase in a facility’s costs.” Medicare Program; Prospective Payment System for

Inpatient Rehabilitation Facilities, 66 Fed. Reg. 41,316, 41,360 (Aug. 7, 2001) (promulgating the

LIP adjustment). For present purposes, the formula by which a facility’s LIP adjustment is

calculated need not be explained in full; it is enough to know that it depends in part on determining

the number of the facility’s patients who were eligible for Medicaid but not entitled to benefits

under Part A of Medicare. See id. (incorporating the “DSH” measure into the LIP adjustment);

Ne. Hosp. Corp. v. Sebelius, 657 F.3d 1, 3, 5 (D.C. Cir. 2011) (explaining the “DSH” measure in

detail).

3 The determination of the prospective payment rates (including LIP adjustment) that a

provider will receive for each of its discharged patients is performed by a contractor serving as the

Secretary’s agent. The contractor makes this determination and issues a notice of total program

reimbursement after receiving detailed cost reports and patient information from the provider. See

42 C.F.R. § 405.1803; id. § 412.604(g). As a general matter, if a Medicare provider is dissatisfied

with a contractor’s final determination of the reimbursement due for a given fiscal year, the

provider may appeal to an administrative tribunal called the Provider Reimbursement Review

Board. 42 U.S.C. § 1395oo(a)(1)(A)(i). The Board’s decision is final unless the Secretary—acting

through the Administrator of the Centers for Medicare and Medicaid Services (CMS)—reverses,

affirms, or modifies the Board’s decision. § 1395oo(f)(1). A provider generally has “the right to

obtain judicial review of any final decision of the Board, or of any reversal, affirmance, or

modification by the Secretary” by filing suit within 60 days. Id.

Plaintiff Mercy Hospital operates an inpatient rehabilitation facility eligible for

reimbursement under Medicare. The Hospital was dissatisfied with the notices of reimbursement

it received from its Medicare contractor for fiscal years 2002, 2003, and 2004. In particular, the

Hospital believed that the contractor had improperly determined its LIP adjustment by taking an

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

Related

Kucana v. Holder
558 U.S. 233 (Supreme Court, 2010)
Gomez v. United States
490 U.S. 858 (Supreme Court, 1989)
Ali v. Federal Bureau of Prisons
552 U.S. 214 (Supreme Court, 2008)
Amgen Inc. v. Scully, Thomas
357 F.3d 103 (D.C. Circuit, 2004)
Amoco Prodn Co v. Watson, Rebecca W.
410 F.3d 722 (D.C. Circuit, 2005)
Southeast Alabama Medical Center v. Sebelius
572 F.3d 912 (D.C. Circuit, 2009)
Northeast Hospital Corp. v. Sebelius
657 F.3d 1 (D.C. Circuit, 2011)
Radlax Gateway Hotel, LLC v. Amalgamated Bank
132 S. Ct. 2065 (Supreme Court, 2012)
MacH Mining, LLC v. Equal Emp't Opportunity Comm'n
575 U.S. 480 (Supreme Court, 2015)
King v. Burwell
135 S. Ct. 2480 (Supreme Court, 2015)
Encino Motorcars, LLC v. Navarro
579 U.S. 211 (Supreme Court, 2016)
Voisine v. United States
579 U.S. 686 (Supreme Court, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
Mercy Hospital, Inc. v. Burwell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mercy-hospital-inc-v-burwell-dcd-2016.