Fox Insurance Company, Inc. v. Centers for Medicare and Medic

OPINION

SCHROEDER, Senior Circuit Judge:

These are two appeals stemming from the government’s immediate termination of a Medicare Part D services contract with a prescription drug insurance coverage provider, Plaintiff-Appellant Fox Insurance Company, Inc. The government terminated the contract in March of 2010 after it had warned Fox of delays in patients’ access to needed medication. Fox had frequently delayed and sometimes completely denied patients’ access to medically necessary drugs by subjecting its enrollees to improper hurdles, such as unnecessary tests and invasive medical procedures,…