We're unable to sign you in at this time. Please try again in a few minutes.
We were able to sign you in, but your subscription(s) could not be found. Please try again in a few minutes.
There may be a problem with your account. Please contact the AMA Service Center to resolve this issue.
Contact the AMA Service Center:
Telephone: 1 (800) 262-2350 or 1 (312) 670-7827  *   Email: subscriptions@jamanetwork.com
Error Message ......
Resident Forum |

Supreme Court Rules Against Teaching Hospitals FREE

[+] Author Affiliations

Section Editor: Ashish Bajaj

JAMA. 1998;279(16):1310M. doi:10.1001/jama.279.16.1310.
Text Size: A A A
Published online

In a 6 to 3 ruling issued in late February, the US Supreme Court said that the US Department of Health and Human Services (DHHS) could recalculate Medicare payments to teaching hospitals dating back to 1984. The ruling is expected to cost US teaching hospitals over $100 million.

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.

In 1989, the DHHS began a reaudit of its 1984 Medicare payments to teaching hospitals and determined that it had overpaid many in 1984. For example, the reaudit found that Medicare had overpaid St Paul-Ramsey Medical Center by more than $4 million in 1984. Because payments for the baseline year were too high, it is likely that payments after 1984 were also too high.

Lawyers for the teaching hospital argued that when the DHHS reaudited payments from 1984, it violated Congress' 3-year time limit. The DHHS argued that because payments in 1984 determined all future payments, they had the right to reaudit that year. The DHHS also stated that its intention was not to recoup any payments more than 3 years old. In its brief, the government argued that "the reaudit rule reflects the (DHHS) Secretary's entirely sensible view that Congress would not have wanted to cement prior errors into all future GME payments simply because reimbursements in certain prior years based on those errors cannot be corrected."

Federal appeals courts were split on the issue. The Supreme Court's ruling determined that the reaudit was "authorized by the Medicare Act" and was not unfairly retroactive. The DHHS would now be able to recalculate and recoup Medicare payments if it had reaudited those payments within the 3-year time limit set by Congress.

This case does not directly relate to the issue of Physicians at Teaching Hospitals (PATH) audits, which primarily concern a reinterpretation of rules regarding supervision and documentation by teaching physicians. The July 25, 1997, and October 22, 1997, Resident Forum columns discussed PATH audits in greater detail.




Also Meets CME requirements for:
Browse CME for all U.S. States
Accreditation Information
The American Medical Association is accredited by the Accreditation Council for Continuing Medical Education to provide continuing medical education for physicians. The AMA designates this journal-based CME activity for a maximum of 1 AMA PRA Category 1 CreditTM per course. Physicians should claim only the credit commensurate with the extent of their participation in the activity. Physicians who complete the CME course and score at least 80% correct on the quiz are eligible for AMA PRA Category 1 CreditTM.
Note: You must get at least of the answers correct to pass this quiz.
Please click the checkbox indicating that you have read the full article in order to submit your answers.
Your answers have been saved for later.
You have not filled in all the answers to complete this quiz
The following questions were not answered:
Sorry, you have unsuccessfully completed this CME quiz with a score of
The following questions were not answered correctly:
Commitment to Change (optional):
Indicate what change(s) you will implement in your practice, if any, based on this CME course.
Your quiz results:
The filled radio buttons indicate your responses. The preferred responses are highlighted
For CME Course: A Proposed Model for Initial Assessment and Management of Acute Heart Failure Syndromes
Indicate what changes(s) you will implement in your practice, if any, based on this CME course.


Some tools below are only available to our subscribers or users with an online account.

0 Citations

Related Content

Customize your page view by dragging & repositioning the boxes below.

Articles Related By Topic
Related Collections
PubMed Articles