Healthkeepers, Inc. v. Richmond Ambulance Authority
2011 U.S. App. LEXIS 8431
4th Cir.2011Background
- The dispute centers on what rate Healthkeepers must pay the Authority for emergency transportation to its Medicaid enrollees.
- The Richmond Ambulance Authority is the sole provider of ambulance emergency services in Richmond and can set its own rates.
- Medicaid’s 1997 amendments created a distinct regime for emergency services, restricting pre-negotiated rates.
- The 2007 Medicaid amendments added § 1396u-2(b)(2)(D), addressing payment amounts for emergency services without contracts with Medicaid managed care entities.
- CMS advised in 2008 that ambulance providers can be providers of emergency services when needed to evaluate or stabilize an emergency.
- The district court granted summary judgment for the Authority; Healthkeepers appealed, and the Fourth Circuit reversed and remanded for summary judgment to Healthkeepers.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether §1396u-2(b)(2)(B) defines emergency services for use in (D) | Healthkeepers—argues (B) applies to (D) | Authority—argues (B) should not bind (D) | Yes; (B) applies to (D) |
| Whether ambulance services fall within outpatient emergency services | Healthkeepers—ambulance services are outpatient emergency services | Authority—ambule services not within outpatient scope | Yes; ambulance services are outpatient emergency services under (B) |
Key Cases Cited
- Barnhart v. Sigmon Coal Co., 534 U.S. 438 (2002) (textual canons and statutory meaning can depend on context)
- United Sav. Ass’n v. Timbers of Inwood Forest Assocs., 484 U.S. 365 (1988) (holistic statutory construction and coherence)
- Helvering v. Stockholms Enskilda Bank, 293 U.S. 84 (1934) (identical language in different parts of an act implies same meaning)
- Sullivan v. Stroop, 496 U.S. 478 (1990) (consistency in usage of terms in statute; dictionaries vary)
- United States v. Joshua, 607 F.3d 379 (4th Cir. 2010) (statutes should be interpreted to avoid absurd results)
- Circuit City Stores, Inc. v. Adams, 532 U.S. 105 (2001) (where general words follow specific words, give meaning to the general terms)