Judicial Review Denied: Lessons Learned from the NAHC’s Case on HHS Payment System

A federal court in Washington DC recently ruled against a lawsuit filed by the National Association for Home Care & Hospice (NAHC) against the Department of Health and Human Services (HHS) regarding a payment system that has significantly reduced reimbursements for numerous home health agencies since 2020. The US District Court for the District of Columbia made this decision in a memorandum opinion on April 26, stating that the plaintiffs did not follow proper procedures by failing to exhaust their administrative remedies before filing the lawsuit.

The court denied NAHC’s own motion, which sought to have the payment system declared unlawful. The ruling indicates that the agency’s process for seeking expedited judicial review should have been pursued by the plaintiffs before resorting to legal action. By bypassing this process, the court found that the plaintiffs did not meet the necessary requirements to bring their case before the court.

Despite this setback, NAHC and other organizations can still learn from this decision and take steps to ensure they properly follow procedures when challenging government policies in the future. The ruling emphasizes the importance of following proper administrative procedures before seeking legal action, as it ensures that all available options are exhausted before taking legal action. Moving forward, it is likely that NAHC and other organizations will be more careful to adhere to these procedures when challenging government policies in order to avoid similar setbacks in future cases.