Hoag Memorial Hospital Presbyterian v. Price, No. 15-56547 (9th Cir. 2017)
Annotate this CaseThe Ninth Circuit held that the Secretary erred in approving a state plan amendment (SPA) pursuant to 42 U.S.C. 1396(a)(30)(A), without requiring any evidence regarding the extent that such care and services were available to the general population in the geographic area. In this case, the Secretary's approval of the SPA absent considerations of some form of comparative-access data was arbitrary and capricious. Accordingly, the court reversed the district court's grant of summary judgment in favor of the Secretary and remanded.
Court Description: Medicaid. The panel reversed the district court’s summary judgment entered in favor of the Secretary of U.S. Department of Health and Human Services, and held that the Secretary’s approval of a state plan amendment retroactively implementing a 10% rate reduction for outpatient services provided to beneficiaries of California’s Medicaid program violated 42 U.S.C. § 1396(a)(30)(A)(“§ 30(A)”), and was arbitrary and capricious. The panel held that the Secretary erred in approving the state plan amendment pursuant to § 30(A) without requiring any evidence regarding “the extent that such care and services are available to the general population in the 6 HOAG MEMORIAL V. PRICE geographic area.” The panel held that the Secretary’s implicit interpretation of § 30(A) conflicted with the statute’s plan language, and was not entitled to Chevron deference. The panel remanded for further proceedings.
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