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Challenge to rulesFinal

Texas Medical Association v. U.S. Department of Health and Human Services (TMA I)

E.D. Tex. · Updated

Summary

TMA challenged the September 2021 interim final rule that told IDR entities to presume the qualifying payment amount (QPA) was the appropriate payment. On February 23, 2022, the Eastern District of Texas vacated those provisions as contrary to the Act and issued without notice and comment. The government's Fifth Circuit appeal was voluntarily dismissed on October 24, 2022.

Timeline of rulings

  1. 5th Cir.

    Government's appeal (No. 22-40264) dismissed on appellant's unopposed motion.

    Read the ruling
  2. E.D. Tex.

    Summary judgment for plaintiffs; provisions of the September 2021 interim final rule giving the QPA presumptive weight vacated as conflicting with the Act and issued without required notice and comment.

    Read the ruling

Why it matters

TMA I removed the rebuttable QPA presumption from the IDR process and began the series of Tyler Division rulings that have repeatedly vacated the Departments' IDR rules.

Related insights

Sources

  1. TMA I, Memorandum Opinion and Order (E.D. Tex. Feb. 23, 2022)
  2. O'Neill Institute tracker — TMA I

General information only, not legal advice. Verdict Consulting Group is not a law firm.