- Court: United States Supreme Court
- Area(s) of Law: Administrative Law
- Date Filed: January 22, 2013
- Case #: 11-123
- Judge(s)/Court Below: Ginsburg, J., for a unanimous Court. Sotomayor, J., concurring.
- Full Text Opinion
In 1983, Medicare began using a “prospective payment system to reimburse hospitals for operating costs based on nationally applicable rates, subject to rate adjustments.” The disproportionate share hospital (DSH) payment allows for additional compensation to hospitals serving large numbers of low-income patients. In 2006 Respondents filed claims with the Provider Reimbursement Review Board (PRRB) seeking full reimbursement for the period of 1987-1994.
Respondents conceded that their claim was outside of the relevant statute of limitations, but argued that the limitation period should be equitably tolled to allow their claim. The PRRB held that it lacked jurisdiction to decide Respondents’ appeal. The District Court held that the Medicare statute does not authorize equitable tolling. The Court of Appeals for the District of Columbia Circuit reversed, and held that the 180 day period for requesting an appeal is subject to equitable tolling.
The Supreme Court emphasized a bright line rule in deciding jurisdiction, deferring to whether Congress has “clearly stated” that the rule is jurisdictional. Absent such clear intent, limitations such as the 180 day appeal restriction are treated as non-jurisdictional. Thus, the Secretary’s three year extension for good cause was appropriate. The Court also stated that the Secretary’s action is entitled to Chevron deference when it is not “arbitrary, capricious, or manifestly contrary to the statute” and held that equitable tolling is inapplicable when the appeals period fell within the scope of deference announced.