The government's best offense is deference: the decision of the Supreme Court in Shalala v. Guernsey Memorial Hospital.
The United States Supreme Court agreed with the Secretary of Health and Human Services that Guernsey Memorial Hospital's advance refunding transaction costs would be subject to a medicare reimbursement policy that is not based upon generally accepted accounting principles. According to the sharp dissent in this case, this policy, set forth in a manual provision, contradicts federal regulations.
Roth
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Dechert Price & Rhoads, Washington, DC, USA.
D000066:Accounting / Q000331:legislation & jurisprudence; D014487:Centers for Medicare and Medicaid Services, U.S. / Q000331:legislation & jurisprudence*; D005377:Financial Management, Hospital / Q000331:legislation & jurisprudence*; D008370:Manuals as Topic; D016344:Medicare Part A / Q000331:legislation & jurisprudence*; D012051:Reimbursement Mechanisms / Q000331:legislation & jurisprudence*; D014481:United States