United States Fourth Circuit

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Children's Hospital of the King's Daughters, Inc. v. Azar, 17-2237

Affirmed an order enjoining the U.S. Department of Health and Human Services from enforcing a Medicaid reimbursement policy that was set forth in a Frequently Asked Questions document. The plaintiff, a hospital, contended that the reimbursement policy was not validly promulgated because there was no formal rulemaking as required by the Administrative Procedure Act. Agreeing, the Fourth Circuit held that the FAQ document was insufficient and that notice-and-comment rulemaking was necessary.

Appellate Information

  • Decided
  • Published 2018/07/23


  • Wynn


  • United States Fourth Circuit