Myndfull Care Management California v. Becerra
3:24-cv-01623
| S.D. Cal. | Dec 30, 2024Background
- Myndfull Care Management California (“Myndfull”) sought to stop the Secretary of Health and Human Services from collecting $6.3 million in alleged Medicare overpayments.
- Qlarant Integrity Solutions, a contractor, conducted a sample review of Myndfull’s Medicare claims and extrapolated an overpayment from that sample.
- Myndfull argued that such extrapolation was unauthorized, as only the Secretary may make the requisite statutory determinations for extrapolation.
- Myndfull had filed a request for redetermination (administrative appeal) with the Secretary, still pending at this lawsuit’s filing.
- Myndfull moved for summary judgment; the Secretary moved to dismiss for lack of subject matter jurisdiction, arguing administrative remedies had not been exhausted.
- The court granted the motion to dismiss, dismissing the case for want of jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction under Medicare Act (presentment) | Presentment met by request for redetermination; exhaustion should be waived | Presentment not met; request for redetermination insufficient | Presentment element satisfied, but exhaustion not met |
| Waiver of exhaustion (irreparable harm) | Irreparable harm because business may close, employees terminated, patient care affected | No irreparable harm; monetary harm not enough in law | No colorable claim of irreparable harm; waiver denied |
| Mandamus jurisdiction | Mandamus proper to force statutory compliance; no other remedy | Mandamus unavailable; administrative appeals process is available | Mandamus denied due to remedy availability and failure to exhaust |
| "No review at all" (Illinois Council exception) | Lack of jurisdiction would entirely bar review | Adequate agency review available; mere delay is not bar | Exception inapplicable; process available |
Key Cases Cited
- Heckler v. Ringer, 466 U.S. 602 (1984) (judicial review of Medicare claims must go through § 405(g) administrative exhaustion)
- Weinberger v. Salfi, 422 U.S. 749 (1975) (final decision required for jurisdiction under § 405(g))
- Mathews v. Eldridge, 424 U.S. 319 (1976) (describes presentment and exhaustion requirements in Medicare/SSA context)
- Shalala v. Illinois Council on Long Term Care, Inc., 529 U.S. 1 (2000) (no review at all exception to administrative exhaustion is narrowly applied)