American Hospital Association v. Becerra
American Hospital Association v. Becerra, 596 U.S. ___ (2022), was a United States Supreme Court case relating to administrative law. The case centered on a rule from the Department of Health and Human Services, which reduced reimbursement rates for certain hospitals. Several hospital associations and hospitals affected by the rule sued HHS, alleging that it exceeded its statutory authority. The court was tasked with deciding if the rule was a reasonable interpretation of the law, and if the statute blocked judicial review of the rule in the first place.[1]
| American Hospital Association v. Becerra | |
|---|---|
 | |
| Argued November 30, 2021 Decided June 15, 2022 | |
| Full case name | American Hospital Association, et al. v. Xavier Becerra, Secretary of Health and Human Services, et al. |
| Docket no. | 20-1114 |
| Citations | 596 U.S. ___ (more) 142 S. Ct. 1896 (2022) |
| Argument | Oral argument |
| Questions presented | |
| |
| Holding | |
| The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 does not preclude judicial review of the reimbursement rates set by the Department of Health and Human Services for certain outpatient prescription drugs that hospitals provide to Medicare patients; in this case, because HHS did not conduct a survey of hospitals’ acquisition costs in 2018 and 2019, its decision to vary reimbursement rates only for 340B hospitals in those years was unlawful. | |
| Court membership | |
| |
| Case opinion | |
| Majority | Kavanaugh, joined by unanimous |
| Laws applied | |
| Medicare Prescription Drug, Improvement, and Modernization Act | |
Background
Rule in question
The rule challenged dealt with 340B hospitals and Medicare Part B insured patients. Previously, the government reimbursed hospitals at a uniform rate if they provided outpatient care to Medicare Part B recipients. HHS then changed the rule to reduce reimbursement rates for 340B hospitals, because they could get drugs at lower costs.[2]
Lower court decisions
The United States District Court for the District of Columbia initially found in favor of the American Hospital Association (AHA), stating the government exceeded its statutory authority. The United States Court of Appeals for the District of Columbia Circuit reversed, finding that the rule was a reasonable interpretation of the law, and applied deference under Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc..[1] On March 15, 2021, the AHA filed a petition for a writ of certiorari.[3]
Supreme Court
The Supreme Court granted certiorari on July 2, 2021, adding a question presented of whether the courts had jurisdiction to consider the challenge to the rule. It heard oral arguments on November 30, 2021. On June 15, 2022, the Supreme Court reversed the D.C. Circuit in a 9–0 decision, written by Justice Brett Kavanaugh.
The court ruled that the statute does not give the Department of Health and Human Services the authority or the discretion to vary the reimbursement rates for 340B hospitals.
Many legal experts considered the case to have significant consequences for the future of Chevron deference, and although the precedent was discussed extensively during oral arguments, the opinion did not mention it even once.[4]
See also
References
- "American Hospital Association v. Becerra". Oyez. Archived from the original on July 17, 2021. Retrieved July 17, 2021.
- "Supreme Court agrees to hear hospital lawsuit challenging HHS' 340B cuts". FierceHealthcare. Retrieved July 17, 2021.
- "American Hospital Association v. Becerra". SCOTUSblog. Retrieved July 17, 2021.
- Romoser, James (June 15, 2022). "In an opinion that shuns Chevron, the court rejects a Medicare cut for hospital drugs". SCOTUSblog. Retrieved June 15, 2022.
External links
- Text of American Hospital Association v. Becerra, 596 U.S. ___ (2022) is available from: Google Scholar Justia Oyez (oral argument audio) Supreme Court (slip opinion)