Hurley v. Bowen
Plaintiff William J. Hurley brought this action to review a final determination by the Secretary of Health and Human Services, denying payment for skilled nursing facility care under Medicare Part A from October 2 to October 23, 1981. Hurley, who suffered a head injury, had his acute care benefits terminated by the hospital's Utilization Review Committee. An Administrative Law Judge (ALJ) twice denied benefits, a decision affirmed by the Appeals Council, on the grounds that he neither required nor received reimbursable skilled nursing facility care. The court affirmed the ALJ's decision, finding it supported by substantial evidence. It noted medical advisor testimony that the care was not inherently complex or exclusively require a skilled nursing facility, and declined to apply the 'treating physician rule' to Dr. Goodman's ambiguous letter.