Monday, October 10, 2022

Nerd Note: Statute that CMS Can't Apply Changes Retroactively

Updates 2023/03

Wolverton at AKIN law firm discusses.

https://www.mondaq.com/unitedstates/healthcare/1033896/going-retro-retroactive-rulemaking-under-the-medicare-statute-and-when-is-a-rule-really-retroactive

Section 102 of H.R.3391 - Medicare Regulatory and Contracting Reform Act of 2001

https://www.congress.gov/bill/107th-congress/house-bill/3391/text?s=1&r=33

I am not sure there is any matching regulation so 1871(e)(1) may be viewed as self implementing and may have no explicit regulatory discussing in the CMS CFR.

An example of CMS going to some detail and claiming retroactivity due to statutory instruction, under proper use of 1871 is found at:  3 FR 29699-711, Long term care hospitals, 5/22/2008.

https://www.govinfo.gov/content/pkg/FR-2008-05-22/html/08-1285.htm



From time to time a company has grounds to protest that an adverse change from CMS is being applied retroactively.  But generally, CMS's hands are tied from retroactive changes.

Here's the regulation.   

https://www.ssa.gov/OP_Home/ssact/title18/1871.htm

Rules and Policy Statements Aren't Retroactive:

(e)(1)(A) A substantive change in regulations, manual instructions, interpretative rules, statements of policy, or guidelines of general applicability under this title shall not be applied (by extrapolation or otherwise) retroactively to items and services furnished before the effective date of the change, unless the Secretary determines that—

(i) such retroactive application is necessary to comply with statutory requirements; or

(ii) failure to apply the change retroactively would be contrary to the public interest.

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This law 1871 also contains a clause, 1871(a)(4), that a final regulation must be a "logical outgrowth" of a proposed regulation, or else it triggers a new public comment period.  For example, CMS could propose a timeline be 12 or 24 months, and finalize at 18 (a logical outgrowth).   But CMS can't propose "Policy A" and finalize as "Policy Z" when Z is wholly different policy that is not a natural outgrowth.  

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For a Supreme Court case hinging on the details of CMS regulatory processses like the quote above, see Alina 2019:

https://www.supremecourt.gov/opinions/18pdf/17-1484_4f57.pdf

Readers might enjoy reading SSA 1871 as a whole. 

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From Fed reg 2008, re a retroactive rule claimed by CMS with detail:

Section 1871(e)(1)(A) of the Act provides that a substantive change 

in regulations, manual instructions, interpretative rules, statements 

of policy, or guidelines of general applicability under this title 

shall not be applied (by extrapolation or otherwise) retroactively to 

items and services furnished before the effective date of the change 

unless the Secretary determines that (i) such retroactive application 

is necessary to comply with statutory requirements; or (ii) failure to 

apply the change retroactively would be contrary to the public 

interest. As explained in the paragraph above, the MMSEA requires the 

Secretary to implement various policy changes either contemporaneously 

with the enactment of the MMSEA on December 29, 2007 or beginning with 

cost reporting periods beginning on or after December 29, 2007 as 

applicable. Therefore, under the authority of section 1871(e)(1)(A)(i) 

of


[[Page 29708]]


the Act, we are making the provisions of this interim final rule with 

comment period that implement sections 114(d) of MMSEA retroactive to 

December 29, 2007. The statute also requires that section 114(c)(1) and 

(2) be implemented beginning with cost reporting periods beginning on 

or after December 29, 2007. Therefore, under the authority of section 

1871(e)(1)(A)(i) of the Act, we are making the provisions of this 

interim final rule with comment period that implement section 114(c)(1) 

and (2) effective for cost reporting periods beginning on or after 

December 29, 2007. Additionally, as explained previously, the Secretary 

also finds that it would be contrary to the public interest if these 

provisions were not made effective on December 29, 2007 or for cost 

reporting periods beginning on or after December 29, 2007, as indicated 

above. Therefore, under the authority of section 1871(e)(1)(A)(ii) of 

the Act, we are making these changes effective under the timeframe 

noted above.

    For the same reasons noted above, we find good cause under section 

553(d)(3) of the APA to waive the 30-day delay in effective date.

tagssa

tagretroactive