In an April 7, 2014 decision, the United States Court of Appeals for the Ninth Circuit upheld CMS’s decision to penalize a hospital more than $500,000 for the late submission of quality data. The hospital had a contract with a third-party vendor to submit data on the hospital’s behalf for the Reporting Hospital Quality Data for Annual Payment Update (RHQDAPU) Program. The vendor did not submit the data to CMS until 12 hours after the established deadline. The hospital argued that the late submission was inconsequential to the RHQDAPU Program’s objectives, but the court held that CMS’s strict adherence to the deadline – and the agency’s decision to hold hospitals responsible for the actions of third-party vendors – was not arbitrary and capricious. The opinion is available here.