Sebelius v. Auburn Regional Medical Center
133 S. Ct. 817
| SCOTUS | 2013Background
- 130 Medicare providers challenge 180-day appeal deadline to PRRB for inpatient reimbursement determinations.
- 1974 regulation allowed a good-cause extension up to three years; three-year outer limit remains in place.
- Dispute arises from Baystate data miscalculation of SSI fraction, which CMS corrected in 2006 and published in 2006–2007.
- Providers argued equitable tolling should apply due to CMS's concealment of faulty SSI data.
- Courts split on whether the 180-day limit is jurisdictional and whether tolling can apply to internal administrative appeals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether §1395oo(a)(3) time limit is jurisdictional. | Hospitals contend it is jurisdictional. | Secretary argues it is nonjurisdictional and extendable. | Not jurisdictional; extendable under regulation. |
| Whether equitable tolling applies to PRRB internal appeals. | Equitable tolling should apply due to CMS concealment. | Tolling does not apply to administrative appeals under statute. | Equitable tolling does not apply. |
| Whether the Secretary’s three-year good-cause extension regulation is permissible. | Regulation improperly expands time via agency rulemaking. | Regulation is a permissible extension under Chevron framework. | Permissible interpretation extending time to three years. |
Key Cases Cited
- Henderson v. Shinseki, 562 U.S. 428 (2011) (jurisdictional interpretation and timeliness principles)
- Arbaugh v. Y&H Corp., 546 U.S. 500 (2006) (bright-line jurisdictional test and context)
- Bowles v. Russell, 551 U.S. 205 (2007) (jurisdictional labeling and time limits)
- Kontrick v. Ryan, 540 U.S. 443 (2004) (filing deadlines as nonjurisdictional in many contexts)
- Zipes v. Trans World Airlines, 455 U.S. 385 (1982) (equitable relief in regulatory time limits)
- Irwin v. Department of Veterans Affairs, 498 U.S. 89 (1990) (presumption of tolling for suits against United States)
- Your Home Visiting Nurse Services, Inc. v. Shalala, 525 U.S. 449 (1999) (administrative remedies and notice in Medicare context)
- Chevron U.S.A. Inc. v. NRDC, 467 U.S. 837 (1984) (deferential deference to agency regulations)
- Brand X Internet Services v. FCC, 545 U.S. 967 (2005) (agency interpretations and statutory meaning)
- Bowen v. City of New York, 476 U.S. 467 (1986) (equitable tolling in remedial contexts)