Lawrence + Memorial Hosp. v. Burwell, No. 15-164 (2d Cir. 2016)
Annotate this CaseIn 2000, the Secretary of Health and Human Services issued a regulation, known as the “reclassification rule,” 42 C.F.R. 412.230(a)(5)(iii), which provided that a hospital that has been reclassified from urban to rural under the Medicare Act, 42 U.S.C. 1395ww(d)(8)(E), may not thereafter receive an additional reclassification by the Medicare Geographic Classification Review Board (MGCRB) for reclassification as urban under subsection (d)(10). Lawrence filed suit seeking a preliminary injunction to enjoin defendants from applying the Secretary's reclassification rule to Lawrence's MGCRB application. The district court denied the motion. However, the court found the statutory language to be plain and unambiguous, and at odds with the Secretary’s reclassification rule, 42 C.F.R. 412.230(a)(5)(iii). Therefore, the court declared the regulation invalid and reversed the judgment of the district court, remanding for a determination of the appropriate remedy.
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