Kearney Regional Medical Center, LLC v. US Department of Health and Human Services, No. 17-1207 (8th Cir. 2019)
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Kearney sought judicial review of the Board's decision denying its application to participate in the Medicare program. Although the facility later received approval, the initial denial prevented Kearney from participating in Medicare and receiving reimbursements for 87 days during 2014.
The Eighth Circuit held that the Board failed adequately to explain the legal standard that it applied in resolving Kearney's administrative appeal. In this case, the court was unable to discern what meaning the Board attributed to 42 U.S.C. 1395x(e)(1) and the definition of "hospital." Furthermore, without an adequate explanation for what time period the agency considered in determining whether Kearney was primarily engaged in providing care to inpatients, the court was unable to resolve whether the Board's decision correctly applied the relevant legal standards. Therefore, the court reversed the district court's grant of summary judgment to the Department and remanded with directions.
Court Description: Colloton, Author, with Smith, Chief Judge, and Beam, Circuit Judge] Civil case - Medicare. Kearney sought judicial review of a decision by the U.S. Department of Health and Human Services Departmental Appeals Board preventing Kearney from participating in Medicare and receiving reimbursements for an 87-day period in 2014. The District Court granted summary judgment to the Department and Kearney appeals. Held: the Appeals Board failed to adequately explain the legal standard it applied in resolving Kearney's administrative appeal; the court is simply unable to discern what meaning the Appeals Board attributed to 42 U.S.C. Sec. 1395x(e)(1) and the definition of hospital; without an adequate explanation for what time period the agency considered in determining whether Kearney was "primarily engaged" in providing care, the court cannot resolve whether the Appeals Board's decision correctly applied the relevant legal standards; the judgment is reversed and remanded with directions to return the case to the agency.
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