Texas Medical Association v. U.S. Department of Health and Human Services (TMA IV)
E.D. Tex. · Updated
Summary
Providers challenged the Departments' December 2022 guidance raising the IDR administrative fee to $350 and the September 2021 interim final rule's batching restrictions. On August 3, 2023, the Eastern District of Texas vacated the $350 fee and the batching provisions for bypassing notice and comment, but denied fee refunds and a deadline extension.
Timeline of rulings
- E.D. Tex.
Summary judgment granted in part: $350 administrative fee guidance (Dec. 23, 2022) and the September 2021 interim final rule's batching provisions vacated and remanded for lack of notice and comment; refunds and deadline extension denied; annual fee-guidance provision upheld.
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Why it matters
TMA IV forced the Departments to reset the IDR administrative fee and batching rules, and it is the background to later fee rulemaking under the IDR operations rules.
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Sources
General information only, not legal advice. Verdict Consulting Group is not a law firm.