Medicare rules for dialysis payments
Marietta Memorial Hospital Employee Health Benefit Plan v. DaVita
In brief
The Supreme Court said Marietta’s uniform outpatient-dialysis coverage did not violate the Act, overturned the Sixth Circuit’s ruling, and sent the case back to that court (reversed and remanded).
- Where it stands
- Decided
Decided 7-2 · June 21, 2022 · Opinion by Justice Kavanaugh
- What it’s about
- DaVita, a dialysis provider, argued that the Marietta Memorial Hospital Employee Health Benefit Plan’s uniform outpatient-dialysis payments disadvantaged people with end-stage renal disease under the Medicare Secondary Payer Act.
- Who it affects
- The ruling means unequal effects alone cannot make a plan legally responsible under this provision. Uniform outpatient-dialysis terms therefore do not violate the Act simply because they affect people with end-stage renal disease differently.
Summary: written with AI from the case record.
What it's about
The Supreme Court ruled that the Act does not allow liability based only on unequal effects and that the plan did not violate the Act; it overturned the Sixth Circuit’s ruling (reversed) and sent the case back to that lower court (remanded).
The case tested whether the Medicare Secondary Payer Act, a law coordinating private health plans with Medicare, also bars uniform terms that allegedly disadvantage people with end-stage renal disease.
Question presented
1. Congress enacted the Medicare Secondary Payer Act as a means to conserve Medicare resources. Among other things, the Act provides that group health plans may not "take into account" the fact that a plan participant with end stage renal disease is eligible for Medicare benefits. Does a group health plan that provides uniform reimbursement of all dialysis treatments observe that prohibition? 2. Under the Medicare Secondary Payer Act, a group health plan also may not "differentiate" between individuals with end stage renal disease and others "in the benefits it provides." Does a plan that provides the same dialysis benefits to all plan participants, and reimburses dialysis providers uniformly regardless of whether the patient has end stage renal disease, observe that prohibition? 3. Is the Medicare Secondary Payer Act a coordination-of-benefits measure designed to protect Medicare, not an antidiscrimination law designed to protect certain providers from alleged disparate impact of uniform treatment?
What the Court decided
Holding
Section 1395y(b)(1)(C) does not authorize disparate-impact liability, and the Marietta Plan’s coverage terms for outpatient dialysis do not violate §1395y(b)(1)(C) because those terms apply uniformly to all covered individuals. 978 F. 3d 326, reversed and remanded.
- Result
- Reversed
The vote
From the opinions
“Today the Court crafts for the Medicare Secondary Payer Act (MSPA) a massive and inexplicable workaround.”
What's next
The Supreme Court sent the case back to the Sixth Circuit (remanded it) for further proceedings. The appeals court must apply the Supreme Court’s rule that uniform coverage terms do not violate this provision.
Documents
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More questions
- What did Marietta v. DaVita decide?
- The Court decided that the Act does not allow a plan to be held legally responsible based only on unequal effects. It also said Marietta’s uniform outpatient-dialysis coverage did not violate the Act.
- What did DaVita argue about Marietta’s plan?
- DaVita, a dialysis provider, argued that uniform outpatient-dialysis payments disadvantaged people with end-stage renal disease under the Act.
- What does the ruling mean for uniform dialysis payments?
- Uniform outpatient-dialysis terms do not violate this provision solely because they affect people with end-stage renal disease differently.
- What happens next in Marietta v. DaVita?
- The Supreme Court sent the case back to the Sixth Circuit (remanded it) for further proceedings under the ruling.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.