University of Chicago Medical Center v. Burwell

CourtDistrict Court, District of Columbia
DecidedJune 26, 2024
DocketCivil Action No. 2016-1276
StatusPublished

This text of University of Chicago Medical Center v. Burwell (University of Chicago Medical Center 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
University of Chicago Medical Center v. Burwell, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNIVERSITY OF CHICAGO MEDICAL CENTER,

Plaintiff,

v. Case No. 16-cv-1276 (DLF)

XAVIER BECERRA, Secretary, U.S. Department of Health and Human Services,

Defendant.

MEMORANDUM OPINION

In this Medicare case, the University of Chicago Medical Center seeks review of a 2015

decision by the Provider Reimbursement Review Board. For the following reasons, the Court will

deny the petition for review.

I. BACKGROUND

A. Statutory and Regulatory Background

The federal Medicare statute funds health care for older Americans. See, e.g., Fischer v.

United States, 529 U.S. 667, 671 (2000). Under the statute, hospitals providing care can generally

recoup their reasonable costs from the federal government. See 42 U.S.C. § 1395g. Whether a

hospital’s costs are reasonable depends in part on a complicated statutory formula, see id.

§ 1395ww(d)(5)(B), the details of which are not important here.

The Secretary of the Department of Health and Human Services has promulgated

regulations that specify how hospitals may request reimbursement for their reasonable costs.

Under those regulations and by statute, hospitals “submit cost reports to contractors . . . known as fiscal intermediaries.” Sebelius v. Auburn Reg’l Med. Ctr., 568 U.S. 145, 150 (2013). If a hospital

“is dissatisfied with the intermediary’s reimbursement determination,” it can appeal it to the

Provider Reimbursement Review Board, a subcomponent of the Department. Id.; see 42 U.S.C.

§ 1395oo. Hospitals that disagree with the Board’s decisions can seek judicial review “in the

district court of the United States for the judicial district in which [they are] located . . . or in the

District Court for the District of Columbia.” 42 U.S.C. § 1395oo(f)(1).

The Board has “full power and authority to make rules and establish

procedures . . . necessary or appropriate to carry out” its responsibilities. Id. § 1395oo(e). Circa

2005—the time period relevant to this case—the Board’s rules and procedures required any

“request for [a] Board hearing” (i.e., any notice of appeal) to “identify the aspects of [a]

determination with which” an appellant was “dissatisfied” and “explain why the [appellant]

believe[d] the determination [was] incorrect in such particulars.” 42 C.F.R. § 405.1841 (2005);

Admin. Record (“AR”) at 6, Dkt. 49. The Board’s rules for appellants elaborated as follows:

Your hearing request must contain an identification and statement of the issue(s) you are disputing. . . . You must clearly and specifically identify your position in regard to the issues in dispute. For instance, if you are appealing an aspect of the disproportionate share (DSH) adjustment factor or calculation, do not define the issue as “DSH.” You must precisely identify the component of the DSH issue that is in dispute. For example: Were the Intermediary’s adjustments to the number of available beds for disproportionate share (DSH) qualification purposes proper?

Provider Reimb. Rev. Bd. Instructions (“PRRB Instr.”) Part I § B.II.a (2002). In addition, in 2008,

the Board promulgated a rule limiting appellants’ rights to add new issues to old appeals. As to

appeals then pending before the Board—again, the subset of appeals relevant to this case—the rule

required appellants to raise such issues to the Board on or before October 20, 2008. AR 6–7; 42

C.F.R. § 405.1835(c)(3) (2008); 73 Fed. Reg. 30190, 30236 (May 23, 2008).

2 B. Factual Background and Procedural History

This case involves a 2005 appeal to the Board. In 2002, the University of Chicago Medical

Center filed a Medicare reimbursement request with its fiscal intermediary. Compl. ¶ 20, Dkt. 1.

The record does not contain a copy of the Center’s request, but the parties agree that it included

reimbursement for over $2 million based on certain time the Center’s medical residents spent

conducting research tasks (“research time”); certain time they spent participating in lectures and

other teaching activities (“didactic time”); certain time they spent on paid vacation (“vacation

time”); certain time spent on clinical rotations (“clinical rotation time”); and certain additional

items carried forward from the prior fiscal year (“carry-forward”). Id. ¶¶ 37, 42; AR 5–7, 15. They

also agree that its reimbursement calculations presumed that the Center operated 417 reimbursable

adult and pediatric hospital beds. See AR 261, 422.1

In 2004, the Center’s fiscal intermediary issued a reimbursement determination. AR 180.

The determination denied the Center’s reimbursement requests for research time, didactic time,

vacation time, clinical rotation time, and carry-forward. See, e.g., AR 3. Further, it calculated

the Center’s total allowable reimbursement starting from the assumption that it operated 417

reimbursable adult and pediatric beds. AR 422; see AR 393.

In 2005, the Center appealed to the Board. AR 243. Its appeal papers read as follows:

The [Center] is dissatisfied with the Intermediary’s determination . . . as to the total number of [its] full-time equivalent (FTE) residents used for purposes of calculating [its] indirect medical education (“IME”) payments. The [Center] contends that the Intermediary’s determination is contrary to 42 U.S.C. § 1395ww(d)(5)(B) because it fails to include time spent by residents performing research and training required as part of their approved residency programs.

1 Each of these variables is an input into the Medicare reimbursement formula mentioned above. See 42 U.S.C. § 1395ww(d)(5)(B). Again, the details of the formula are not important to this case. 3 AR 1079. In 2006, it added another issue to its appeal: “Improper inclusion of beds from the

Clinical Research Center.” AR 1068. The Center argued that—in fact—it operated eight fewer

reimbursable hospital beds than was presupposed, entitling it to approximately $700,000 more in

reimbursement under the applicable statutory formula. AR 1068, 1072.

In 2012, the Center filed a position paper before the Board. AR 355. The position paper

sought reimbursement for didactic time, vacation time, clinical rotation time, and carry-forward as

well as research time. See AR 356. In response, the fiscal intermediary objected that the Center

forfeited the issues besides research time by failing to raise them with the Board before October

20, 2008. AR 357. It also objected that the Center forfeited its reimbursable-beds issue by failing

to raise it in its initial reimbursement request to the fiscal intermediary. See AR 394.

The Board disposed of the Center’s claims in three decisions: one dated May 14, 2014;

another dated July 16, 2015; and another dated February 4, 2016. AR 1–16, 89.2 As to the Center’s

resident-time claims, the Board sided with the Center in part and its fiscal intermediary in part.

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