In the 1985 case Bowen, Secretary of Health and Human Services, et al. v. Michigan Academy of Family Physicians et al., the United States Supreme Court ruled that a Medicare provision barring judicial review of amounts determined for payment under Part B was not applicable to challenges based on statutory or constitutional grounds. The case arose when the Michigan Academy of Family Physicians sued over changes in reimbursement rates for physicians' services under Medicare Part B, arguing they were inconsistent with the Social Security Act's requirements and violated due process rights. The government argued that these claims were barred by section 1395ii which incorporates a provision from Social Security law (section 405(h)) making its decisions unreviewable by any court if it involves "amounts" determinations. However, the Supreme Court held this did not preclude all types of judicial review but only those related to specific amount determinations made in individual cases.

In the dissenting opinion for Bowen, Secretary of Health and Human Services, et al. v. Michigan Academy of Family Physicians et al., Justice White argued that the majority misinterpreted Section 223(g) of the Social Security Act to allow judicial review in this case. He believed that Congress intended to preclude all challenges to regulations concerning amounts paid under Medicare Part B except those brought by providers or suppliers who were directly affected by a final decision from the Secretary regarding their claims for payment. The plaintiffs in this case were not such parties; they were physicians challenging a rule about how much would be paid overall for certain services rather than specific claim determinations made by the Secretary. Therefore, according to Justice White's interpretation, these doctors did not have standing under Section 223(g) because they had no direct financial stake in any particular claim determination made by the Secretary.