Supreme Court of the United States
Thomas Jefferson University, Dba Thomas Jefferson University Hospital v. Shalala
June 24, 1994512 U.S. 504
Summary
The Court, in an opinion by Justice Kennedy, upheld the Secretary’s interpretation of Medicare’s anti-redistribution regulation to prohibit reimbursement of educational costs previously borne by a hospital’s affiliated medical school. The interpretation reasonably reflected the regulation’s language, imposed an operative reimbursement limitation, and was not shown to conflict with a prior agency interpretation. The Court affirmed without deciding the validity of the Secretary’s separate community-support rationale. Justice Thomas dissented, joined by Justices Stevens, O’Connor, and Ginsburg. They considered the regulation merely precatory, found the Secretary’s interpretation inconsistent with prior agency practice, and argued that neither the anti-redistribution provision nor the community-support provision justified denying reimbursement.
Holding
- Validity of the Secretary’s interpretation of the anti-redistribution provision.. The Secretary reasonably interpreted 42 CFR § 413.85(c) to prohibit reimbursement of educational costs previously incurred and paid by an affiliated medical school.
- Effect of alleged inconsistency in prior agency interpretations and practices.. The hospital failed to establish an inconsistent agency interpretation that warranted withholding deference.
- Whether the anti-redistribution language has substantive force.. The Secretary could interpret the anti-redistribution clause as a substantive limitation on reimbursement.
Docket 93-120
Cited authorities
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