Medicare reimburses teaching hospitals for expenses related to providing graduate medical education (GME). The case of Regions Hospital v Shalala brought forth by St Paul-Ramsey Medical Center, a teaching hospital in St Paul, Minn, questioned whether or not the Secretary of the DHHS had the authority to retrospectively reaudit Medicare payments to teaching hospitals. According to federal statute, the DHHS has a 3-year time limit in which it can reopen a previous Medicare payment audit. In 1985, the US Congress issued new rules regarding Medicare payments to teaching hospitals. The new rules set fiscal year 1984 as a baseline year that would be used to determine subsequent payments.