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Temple Univ. Hosp. v. Sec’y U.S. Dep’t of Health and Human Servs.

3rd Circuit

June 21, 2021

This case involved a dispute between a hospital and a federal agency over Medicare reimbursements. The core controversy concerned the hospital’s geographical-area assignment for purposes of the wage index, which is used to calculate those reimbursements. The hospital did not pursue its claim through administrative adjudication before suing in federal court. The District Court ruled in favor of the agency officials. The Third Circuit vacated and remanded with instructions to dismiss the complaint. The Third Circuit ruled that by not following the statutory channeling requirement, the hospital had no valid basis to invoke the District Court’s subject-matter jurisdiction.

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