UNIVERSITY OF WASHINGTON MED. CENTER v. Sebelius
634 F.3d 1029
| 9th Cir. | 2011Background
- Hospitals appeal district court decision upholding Secretary's exclusion of GAU/MI from Medicare DSH calculations.
- Medicare DSH increases reimbursements based on two proxies, including patients eligible for medical assistance under subchapter XIX.
- Washington Medicaid plan extended care to GAU and MI using state funds, indirectly funded by federal Medicaid DSH dollars.
- GAU/MI patients are not categorically or medically needy under Medicaid and are outside traditional Medicaid eligibility.
- State reimburses GAU/MI via a formula using DSH allotment; funds are not tied to individual patients as in traditional Medicaid.
- Secretary concluded GAU/MI were not eligible for medical assistance; Board ruled for Hospitals; Secretary reversed; district court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether GAU/MI are eligible for medical assistance under subchapter XIX | Hospitals: GAU/MI qualify via Medicaid plan language and funding. | Secretary: GAU/MI not eligible; not within enumerated categories. | Not eligible; exclusion upheld. |
| Definition of medical assistance under Medicaid for DSH purposes | Medical assistance includes indirectly funded care via state plans. | Medical assistance is limited to traditional Medicaid eligibility categories. | Medical assistance is limited to Medicaid-eligible individuals. |
| Whether federal funds are spent on GAU/MI care via DSH | DSH funding subsidizes GAU/MI care with federal dollars. | DSH lump sum is not tied to individual care; not spent on GAU/MI as medical assistance. | Federal funds not spent as medical assistance for GAU/MI. |
| Chevron step one applicability | Statute unambiguous in including GAU/MI via plan. | Statute ambiguous; agency permissible construction. | Statute unambiguous; agency258 permissible construction not needed. |
Key Cases Cited
- Legacy Emanuel Hosp. & Health Ctr. v. Shalala, 97 F.3d 1261 (9th Cir. 1996) (medical assistance means payment for Medicaid-eligible care)
- Phoenix Memorial Hosp. v. Sebelius, 622 F.3d 1219 (9th Cir. 2010) (defines medical assistance under Medicaid as statutory term of art)
- Adena Reg'l Med. Ctr. v. Leavitt, 527 F.3d 176 (D.C. Cir. 2008) (limits on what constitutes medical assistance under Medicaid)
- Cooper Univ. Hosp. v. Sebelius, 686 F. Supp. 2d 483 (D.N.J. 2009) (role of Medicaid eligibility in interpreting medical assistance)
- Loma Linda Univ. Med. Ctr. v. Leavitt, 492 F.3d 1065 (9th Cir. 2007) (statutory interpretation of medical assistance under Medicaid)
- Anaheim Mem'l Hosp. v. Shalala, 130 F.3d 845 (9th Cir. 1997) (agency jurisdiction and interpretation of Medicaid provisions)
- Portland Adventist Med. Ctr. v. Thompson, 399 F.3d 1091 (9th Cir. 2005) (administrative review standards for agency decisions)