Merit Health River Region v. Becerra
Civil Action No. 2023-0906
D.D.C.Mar 11, 2025Background
- Merit Health River Region, an acute care provider, challenged Medicare reimbursement determinations for fiscal years 2011 and 2013 before the Provider Reimbursement Review Board (PRRB) of the Department of Health and Human Services (HHS).
- The Board dismissed the appeals after Merit Health failed to submit required final position papers by the deadline.
- Quality Reimbursement Services (QRS), the provider's representative, attributed the missed deadline to the illness and subsequent death of the employee responsible for filings.
- Plaintiff moved for reinstatement, arguing for a good cause exception based on these circumstances, but the Board denied the motion, finding insufficient evidence of good cause.
- Merit Health then sued the HHS Secretary in district court under the Administrative Procedure Act (APA), challenging both the dismissal and the denial of reinstatement.
- Both parties filed cross-motions for summary judgment. The court reviewed the administrative record to determine whether the Board’s actions were arbitrary, capricious, or otherwise not in accordance with law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether dismissal for missing deadline misapplied Board rules | Dismissal is not mandatory; rules allow discretion, but Board treated as required | Dismissal was discretionary; Board properly exercised its option | Board properly exercised its discretionary authority; no error in interpreting rules |
| Whether denial of reinstatement was arbitrary/capricious | Board failed to sufficiently consider reasons for missed deadline | Board reasonably found no good cause given the record | Board’s decision was reasonable and supported by the record; no APA violation |
Key Cases Cited
- Ne. Hosp. Corp. v. Sebelius, 657 F.3d 1 (D.C. Cir. 2011) (overview of administrative procedures for Medicare reimbursement appeals)
- In re Polar Bear Endangered Species Act Listing & Section 4(d) Rule Litig., 709 F.3d 1 (D.C. Cir. 2013) (arbitrary and capricious standard for agency decisions)
- Am. Bioscience, Inc. v. Thompson, 269 F.3d 1077 (D.C. Cir. 2001) (APA review limited to administrative record)