consequences to events completed before its enactment.” Landgraf v. USI Film Products, 511 U.S. 244, 269-70, 114 S.Ct. 1483, 128 L.Ed.2d 229 (1994). The law generally disfavors retroactive rule-making. See Bowen v. Georgetown Univ. Hosp., 488 U.S. 204, 208, 109 S.Ct. 468, 102 L.Ed.2d 493 (1988). The Medicare statute is no exception — it requires an opportunity for notice and comment, and findings by the Secretary, before CMS can implement retroactive, substantive changes in regulations. See 42 U.S.C. §§ 1395hh(a)(l)-(4), 395hh(e)(l)(A). Fayetteville argues that the addition of a temporal limitation to the preamble of paragraph (c)(4)(iii) was a substantive, retroactive change that required notice and comment. See Hardy Wilson Mem’l Hosp. v. Sebelius, 616 F.3d 449, 461 (5th Cir.2010) (<HOLDING>). It also asserts that the Secretary knew the
holding that substantive review is adequate holding court cannot change custody without showing that change is in best interests of child holding that change in state substantive case law does not constitute the removal of an impediment holding that a change of venue has no affect on the applicable state law and that change of venue is but a change of courtrooms holding that the 2005 amendment was a substantive change