Mercy Gen. Hosp. v. Azar
Court of Appeals for the D.C. Circuit
1Opinion of the Court
(1) The debt must be related to covered services and derived from deductible and coinsurance amounts.(2) The provider must be able to establish that reasonable collection efforts were made.(3) The debt was actually uncollectible when claimed as worthless.(4) Sound business judgment established that there was no likelihood of recovery at any time in the future.
Id.
Chapter 3 of CMS's Provider Reimbursement Manual ("PRM") provides further instruction regarding the requirements for bad debt reimbursement. As to the second bad debt criterion, regarding "reasonable collection efforts," § 310…
2Cases cited38 opinions
- Motor Vehicle Mfrs. Assn. of United States, Inc. v. State Farm Mut. Automobile Ins. Co.Supreme Court of the United States · 1983
- Citizens to Preserve Overton Park, Inc. v. VolpeSupreme Court of the United States · 1971
- Pierce v. UnderwoodSupreme Court of the United States · 1988
- Consolo v. Federal Maritime CommissionSupreme Court of the United States · 1966
- Bowman Transportation, Inc. v. Arkansas-Best Freight System, Inc.Supreme Court of the United States · 1975
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3Cited by7 opinions
- Select Specialty Hospital-Denver, Inc. v. AzarCourt of Appeals for the D.C. Circuit · 2019
- Kindred Healthcare, Inc. v. AzarDistrict Court, District of Columbia · 2020
- Mercy General Hospital v. BecerraDistrict Court, District of Columbia · 2022
- Mercy General Hospital v. BurwellDistrict Court, District of Columbia · 2019
- New Lifecare Hospitals of North Carolina LLC v. CochranDistrict Court, District of Columbia · 2019
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