(CN) – Hospitals are not entitled to receive higher Medicare payments for the time residents spend performing research unrelated to patient care, a federal appeals court in Boston ruled.
The 1st Circuit reversed U.S. District Judge Ernest Torres’ decision that the Department of Health and Human Services misread the plain language of the teaching adjustment regulation in Medicare and withheld adjusted payments from Rhode Island Hospital.
In creating the adjustment plan, Congress recognized that teaching hospitals often incur higher costs than non-teaching hospitals for patient care.
But the 1st Circuit found that residents performing research not related to patients are not assigned to a “portion of the hospital subject to the prospective payment system.” The hospital’s argument took a broader view of the statutory language.
“The adjustment’s legislative and administrative history adequately support the Secretary’s conclusion that this provision was intended to compensate teaching hospitals for added costs of patient care unremunerated by the prospective payment system,” Judge Baldock wrote.