El Paso County Hospital District v. Texas Health & Human Services Commission, 400 S.W.3d 72

The case concerns the validity of HHSC's cutoff date for Medicaid data collection used to set inpatient reimbursement rates.
Fourteen Texas hospitals challenged the cutoff, arguing it was an invalid APA rule and that a rule limiting appeals should not bar data-entry-error reviews.
This Court previously held the cutoff date invalid as an unadopted rule and enjoined its enforcement, while leaving room for administrative-appeal review of data-entry errors.
The prior decision remanded to determine retroactive relief for past rate calculations, but it did not decide whether retroactive adjustments would be granted or how they would be implemented.
Subsequently, district court and court of appeals varied on whether injunction relief included retroactive recalculation for FY 2002–2007 and related payments.
HHSC has since recalculated rates without the cutoff in progress of ongoing proceedings, with some hospitals seeing increased or unchanged rates; the dispute then focused on the scope of relief and retroactivity under agency rules and injunctions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Scope of retroactive relief from injunction	Hospitals say judgment reopened past proceedings for retroactive adjustments.	HHSC contends injunction was prospective unless court stated otherwise and did not compel retroactive recalculation.	Retroactive relief not granted by prior judgment; remedy limited by agency rules and injunction scope.
Effect of injunction on data collection and recalculation	Hospitals argued injunction required immediate recalculation without cutoff.	Injunction barred only use of cutoff in data collection for future proceedings, not mandatory immediate recalculation.	Injunction did not mandate immediate retroactive recalculation; affected data review occurs within authorized proceedings.
Retroactivity under Former Rule 355.8063	Rule allowed retroactive adjustments for past years if data were omitted.	Rule limited corrections to current year and future years, not past years.	Former Rule 355.8063 limitations barred retroactive adjustments for FY 2002–2007; only prospective remedies were available.

El Paso Hosp. Dist. v. Tex. Health & Human Servs. Comm’n, 247 S.W.3d 709 (Tex. 2008) (invalidated cutoff as an unadopted APA rule; left open retroactive relief under agency rules; data-entry-review path recognized)
El Paso Hosp. Dist., 351 S.W.3d 460 (Tex.App.-Austin 2011) (affirmed that prior judgment did not reopen past proceedings; interpreted retroactivity scope of injunction)
Gulf States Utils. Co. v. Public Utilities Comm’n, 809 S.W.2d 201 (Tex. 1991) (deference to agency interpretation of its own rules; standards for judicial interpretations of agency rules)