Mealey's (November 30, 2020, 2:11 PM EST) -- SAN FRANCISCO — The Medicare Secondary Payer Act (MSP) private right of action does not require the program to have actually made a payment, a Ninth Circuit U.S. Court of Appeals panel held Nov. 24 in largely reinstating a dialysis reimbursement action (DaVita Inc. v. Virginia Mason Memorial Hospital, et al., No. 19-35692, 9th Cir., 2020 U.S. App. LEXIS 37080)....