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Doyle v. Secretary of Health and Human Services

848 F.2d 296 (1988)

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Doyle v. Secretary of Health and Human Services

United States Court of Appeals for the First Circuit

848 F.2d 296 (1988)

Facts

The secretary of the Department of Health and Human Services (the department) (defendant) contracted with a company to review medical charts and identify possible Medicare violations. The company flagged physician Robert Doyle (plaintiff) for potential violations. The company followed the proper procedures to report the potential violation to the government. The Maine Advisory Committee, which was established to conduct hearings and make sanction recommendations, conducted an administrative hearing and found that Doyle had committed gross and flagrant violations. The advisory committee recommended to the department’s inspector general that Doyle receive a five-year sanction prohibiting him from participating in Medicare. The inspector general ordered the recommended sanction. In response, Doyle filed an action in federal district court seeking judicial review of the sanction. Doyle also claimed that the sanction violated his due-process rights. Doyle alleged that the applicable phrases in the Medicare Act were unconstitutionally vague, such as the requirement to provide adequate healthcare. Additionally, Doyle argued that he should have been afforded a full evidentiary hearing and that the reviewing committees were biased by serving as both prosecutor and judge. The district court enjoined the department from issuing the sanction on the ground that it had not properly considered the statutory factors required by the federal law governing the Medicare program. The department appealed on the ground that Doyle had not exhausted his administrative remedies, as required by federal law. The United States Court of Appeals for the First Circuit reviewed the case.

Rule of Law

Issue

Holding and Reasoning (Breyer, J.)

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