Texas Hospital Association Dallas/Fort Worth Hospital Council Memorial Healthcare System And Hendrick Medical Center v. Texas Workers' Compensation Commission

CourtCourt of Appeals of Texas
DecidedDecember 6, 1995
Docket03-95-00227-CV
StatusPublished

This text of Texas Hospital Association Dallas/Fort Worth Hospital Council Memorial Healthcare System And Hendrick Medical Center v. Texas Workers' Compensation Commission (Texas Hospital Association Dallas/Fort Worth Hospital Council Memorial Healthcare System And Hendrick Medical Center v. Texas Workers' Compensation Commission) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Texas Hospital Association Dallas/Fort Worth Hospital Council Memorial Healthcare System And Hendrick Medical Center v. Texas Workers' Compensation Commission, (Tex. Ct. App. 1995).

Opinion

THA v. TWCC

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN



NO. 03-95-00227-CV



Texas Hospital Association; Dallas/Fort Worth Hospital Council;

Memorial Healthcare System; and Hendrick Medical Center, Appellants



v.



Texas Workers' Compensation Commission, Appellee



FROM THE DISTRICT COURT OF TRAVIS COUNTY, 353RD JUDICIAL DISTRICT

NO. 92-12348, HONORABLE PAUL R. DAVIS, JR., JUDGE PRESIDING



Appellants Texas Hospital Association, Dallas/Fort Worth Hospital Council, Memorial Healthcare System, and Hendrick Medical Center ("the Hospitals") sued in district court for an injunction and a declaratory judgment that a rule promulgated by appellee Texas Workers' Compensation Commission ("the Commission") is void and unenforceable because the Commission failed to satisfy the reasoned-justification requirement of the Administrative Procedure Act. (1) Following a bench trial, the district court rendered judgment denying the relief sought by the Hospitals, who now appeal. We will reverse the district court's judgment and render judgment that the rule is void and that the Commission be enjoined from enforcing it.



THE CONTROVERSY

In 1989, the Texas Legislature significantly amended the Texas Workers' Compensation Act and directed the Commission to set new guidelines for reimbursements to health-care providers treating injured workers. Tex. Labor Code Ann. § 413.011(a)(1) (West 1995). (2) The Legislature provided that the guidelines "must be fair and reasonable and designed to ensure the quality of medical care and to achieve effective medical cost control." Id. § 413.011(b). To fulfill this difficult statutory command, the Commission implemented a completely new method for the calculation of hospital and medical services fees: flat-rate per-diem reimbursement.

In the past, the Commission had set fees at a percentage of the provider's usual charges, with added maximum-payment levels to provide for cost containment. Under the new system, the Commission divided hospital and medical services into broad categories, such as surgical or intensive care, and assigned a fixed per-diem reimbursement for any treatment within the category. The old system accounted for differences in geography and complexity of the procedure because it calculated reimbursements as a percentage of the provider's usual charges. The new fee system breaks with the old reimbursement method in that it applies a fixed per-diem reimbursement without variation for geographic location or the specific medical condition involved. For example, under the new system Methodist Hospital in Houston receives the same per-diem reimbursement for open-heart surgery that a smaller hospital receives for surgery necessitated by a broken leg because both receive the fixed per-diem rate pursuant to the "surgery" category. Under the old system based on provider charges, the two procedures would have yielded significantly different reimbursements.

At issue in this appeal is a rule promulgated by the Commission in 1992 to implement the new per-diem reimbursement system for hospitals providing inpatient, acute-care services. See 28 Tex. Admin. Code § 134.400 (1995) ("Rule 400"). Rule 400 adopts by reference the "Acute Care Inpatient Hospital Fee guideline" ("the guideline"). The guideline sets the per-diem reimbursement rates for the three broad categories of treatment devised by the Commission (medical, surgical, and intensive care). The Commission developed the guideline by analyzing empirical billing data provided by hospitals, devising an average per-diem rate for each broad category of medical service, and adjusting downward by 8.5% for cost containment.

The Hospitals challenged Rule 400 in district court after the Commission adopted the rule by an order published in the Texas Register. 17 Tex. Reg. 4949 (1992) ("the order"). The Hospitals argued that Rule 400 is invalid because the order adopting it did not contain a "reasoned justification," as required by the APA. APA §§ 2001.033(1), 2001.035(a). The district court denied the Hospitals' request for declaratory and injunctive relief, and they now appeal the district-court judgment.



DISCUSSION

The APA requires that an agency order adopting a rule must contain a reasoned justification for that rule. APA § 2001.033(1). A reasoned justification must include the following three elements: a summary of comments the agency received, a restatement of the rule's factual basis, and the reasons why the agency disagrees with a party's comments. Id. In addition to the three minimum criteria, the agency must provide a reasoned justification for the rule as a whole. Railroad Comm'n v. Arco Oil & Gas Co., 876 S.W.2d 473, 492 (Tex. App.--Austin 1994, writ denied); Chrysler Motors v. Motor Vehicle Comm'n, 846 S.W.2d 139, 143 (Tex. App.--Austin 1993, no writ). If the order adopting a rule does not substantially comply with the above requirements within its "four corners," the rule is invalid. APA § 2001.035(a); Methodist Hosps. v. Industrial Accident Bd., 798 S.W.2d 651, 659 (Tex. App.--Austin 1990, writ dism'd w.o.j.). To substantially comply with the APA, a reasoned justification must concisely, specifically, and unambiguously secure the essential legislative objective of "provid[ing] the factual basis and rationality of the rule as determined by the agency." Arco, 876 S.W.2d at 491. We review a challenge to the reasoned-justification requirement using an "arbitrary and capricious" standard, with no presumption that facts exist to support the agency's order. Id.

The Hospitals argue that the Commission failed to substantially comply with its statutory duty to provide, within the four corners of the order adopting Rule 400, a restatement of the rule's factual basis or an independent justification of the rule as a whole. The Commission responds that its order, even if it does not contain a concise and discrete restatement of factual basis or reasoned justification, nevertheless satisfies both requirements through language "woven" into the Commission's responses to the summarized comments. We agree with the Hospitals that the order does not provide a reasoned justification or restate the factual basis of Rule 400 and thus does not substantially comply with the APA requirements.

The Commission claims that several portions of the order satisfy the reasoned justification and factual basis requirements. First, the Commission points to the following:



The commission is required by law to adopt rules to establish guidelines for fees charged or paid for medical services.

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Texas Hospital Association Dallas/Fort Worth Hospital Council Memorial Healthcare System And Hendrick Medical Center v. Texas Workers' Compensation Commission, Counsel Stack Legal Research, https://law.counselstack.com/opinion/texas-hospital-association-dallasfort-worth-hospital-council-memorial-texapp-1995.