Yale New Haven Hosp. v. Becerra, No. 20-2115 (2d Cir. 2022)
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Yale New Haven Hospital (“YNHH”) receives federal funds under the Medicare Act. As part of the statutory formula for determining appropriate funding, the Medicare Act directs the Secretary of Health and Human Services (the “Secretary”) to “estimate” the “amount of uncompensated care” that each hospital will provide to indigent patients in a given federal fiscal year (“FFY”). Here, YNHH contended that the Secretary failed to conduct adequate notice-and-comment rulemaking before choosing to use only YNHH’s historical data – and not that of a hospital that had recently merged into YNHH – to estimate YNHH’s amount of uncompensated care for FFY 2014. The Secretary moved to dismiss for lack of subject-matter jurisdiction under 42 U.S.C Section 1395ww(r)(3), which prohibits “judicial review” of “[a]ny estimate of the Secretary.” The district court denied the Secretary’s motion, reasoning that section 1395ww(r)(3) applies only to substantive challenges to estimates, but not to procedural challenges like YNHH’s. The district court subsequently granted summary judgment in favor of YNHH.
The Secretary appealed, disputing (1) the district court’s ruling that it had jurisdiction to consider YNHH’s procedural challenge, and alternatively (2) the district court’s merits ruling that the Secretary’s estimate was procedurally unlawful.
The Second Circuit reversed the district court’s denial of the Secretary’s motion to dismiss YNHH’s procedural challenge for lack of subject-matter jurisdiction; vacated, for lack of subject-matter jurisdiction, the district court’s grant of summary judgment for YNHH on its procedural challenge; REMAND the case to the district court with instructions to dismiss the remainder of YNHH’s action for lack of subject-matter jurisdiction; and dismissed YNHH’s cross-appeal disputing the district court’s chosen remedy.
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