The Impact of the Loper Bright Decision on Agency Deference and Health Care Law

Supreme Court Decision in Loper Bright Case Changes Landscape of Agency Deference in Health Care Industry

In a groundbreaking decision, the Supreme Court has overturned the long-standing Chevron deference doctrine, which required federal courts to defer to agency interpretations of ambiguous statutes. The consolidated opinion in Loper Bright Enterprises v. Raimondo and Relentless, Inc. v. Department of Commerce has set a new precedent, requiring courts to exercise independent judgment in interpreting statutory provisions, particularly impacting the health care industry.

The Chevron deference doctrine, established in Chevron USA. v. National Resource Defense Council, allowed courts to defer to agency interpretations of statutes when the language was silent or ambiguous. However, the Loper Bright decision has shifted the power back to the courts, emphasizing that judges, not agencies, should interpret the law.

The case at the center of this decision involved fishing companies challenging regulations under the Magnuson-Stevens Act, which required them to pay for federal observers onboard their vessels. The Supreme Court ruled that the agency’s interpretation was not entitled to deference, signaling a significant change in how courts will approach agency rulemaking and actions.

This decision has far-reaching implications for the health care industry, which is heavily regulated by agencies like the US Department of Health and Human Services. With the Chevron deference doctrine no longer in play, challenges to agency interpretations and rulemakings are expected to increase. Health care organizations may face uncertainty as courts grapple with the complexity of health care statutes and regulations.

The new standard set by the Loper Bright decision, coupled with the recent Corner Post v. Federal Reserve ruling, which alters the statute of limitations for challenging agency actions, will likely lead to a more scrutinized regulatory landscape in the health care industry. Health care organizations will need to navigate these changes carefully to ensure compliance and mitigate risks in this evolving legal environment.