Episode 111
Opinion Summary: Advocate Christ Medical Center v. Kennedy | Date Decided: 4/29/25 | Case No. 23-715
The question presented in this case is: Does the phrase "entitled ... to benefits," used twice in the same sentence of the Medicare Act, mean the same thing for Medicare part A and supplementary security income (SSI), such that it includes all who meet basic program eligibility criteria, whether or not benefits are actually received.
The Supreme Court held: In calculating the Medicare fraction, an individual is “entitled to[SSI] benefits” for purposes of the Medicare fraction when she is eligible to receive an SSI cash payment during the month of her hospitalization.
Transcript
The question presented in this case is does the phrase entitled to benefits used twice in the same sentence of the Medicare act mean the same thing for Medicare Part A and SSI such that it includes all who meet basic program eligibility criteria, whether or not benefits are actually received?
Speaker A:Justice Barrett delivered the opinion of the Court in which Chief Justice Roberts and Justices Thomas Alito, Kagan, Gorsuch, and Kavanaugh joined.
Speaker A:Justice Jackson filed a dissenting opinion in which Justice Sotomayor joined.
Speaker A:Please note that this summary is read by an automated voice.
Speaker B:Justice Barrett's majority opinion when hospitals provide inpatient services to Medicare beneficiaries, the Medicare program pays those hospitals a fixed rate for treating each Medicare patient.
Speaker B: USC Sections: Speaker B:Congress also provides various hospital specific rate adjustments, including the disproportionate share hospital adjustment, which offers additional funding to hospitals that treat a high percentage of low income patients.
Speaker B: the Medicaid fraction section: Speaker B:The Medicare fraction represents the proportion of a hospital's Medicare patients who have low incomes and the Medicaid fraction represents the proportion of a hospital's patients who are not entitled to Medicare and have low incomes.
Speaker B:Becerra vs.
Speaker B:Empire Health foundation for Valley Hospital Medical Center, 597 U.S.
Speaker B: ,: Speaker B:That percentage in turn, determines whether a hospital will receive a DSH adjustment and if so, how much.
Speaker B: , section: Speaker C:Double P double F, double V, double I, double I.
Speaker B: quoting section: Speaker B:Alteration in original but the court has not addressed the issue presented in this case, that is which patients count as being entitled to SSI benefits under subchapter 16.
Speaker B:HHS interprets the language to mean patients who are entitled to receive an SSI payment during the month in which they were hospitalized.
Speaker B:Petitioners, a group of more than 200 hospitals, insist that the phrase includes all patients enrolled in the SSI system at the time of their hospitalization, even if they were not entitled to an SSI payment during their month of hospitalization.
Speaker B: nderfunded the hospitals from: Speaker B:The hospitals have lost at every stage of this litigation, including most recently before the D.C.
Speaker B:circuit.
Speaker B:The D.C.
Speaker B:circuit concluded that SSI benefits in subchapter 16 are about cash payments for needy individuals and that it makes little sense to say that individuals are entitled to the benefit in months when they are not even eligible for a payment.
Speaker B:Advocate Christ Medical Center v.
Speaker B: Becerra, ADF: Speaker B:The court granted certiorari held in calculating the Medicare fraction, an individual is entitled to SSI benefits for purposes of the Medicare fraction when she is eligible to receive an SSI cash payment during the month of her hospitalization.
Speaker B:Pages 6 to 16A.
Speaker B:SSI benefits are cash benefits.
Speaker B:C.
Speaker B: , Section: Speaker B: Section: Speaker B:A benefit quantified in dollar amounts is plainly a cash benefit.
Speaker B:Similarly, subchapter 16's codified statement of purpose is to provide Supplemental Security income to individuals.
Speaker B: Section: Speaker B:Just as subchapter 16 makes clear that SSI benefits are cash benefits, it also establishes that eligibility for such benefits is determined on a monthly basis.
Speaker B: Section: Speaker B:The statute's reference to termination of benefits also refers back to months of ineligibility, stating that an individual must reapply for the program after she has been ineligible for benefits for a period of 12 consecutive months.
Speaker B: Section: Speaker B:Finally, although subchapter 16 speaks primarily in terms of eligibility for SSI benefits, the Medicare fraction focuses on whether an individual is entitled to such benefits.
Speaker B:Nothing turns on this difference.
Speaker B:In Empire Health, the Court treated the word entitled in the Medicare statute as synonymous with qualifying for or being eligible for benefits.
Speaker B:597 US at 435.
Speaker B:This case also involves the Medicare fraction, so the Court follows the same course.
Speaker B:Because eligibility for an SSI payment is determined on a monthly basis, an individual is considered entitled to SSI benefits for purposes of the Medicare fraction when she is eligible for such benefits during the month of her hospitalization.
Speaker B:Pages 6 9b the hospital's broader reading of entitled to SSI benefits fails.
Speaker B:Pages 9 to 161 while the hospitals characterize SSI benefits as including non cash benefits, e.g.
Speaker B:vocational rehabilitation services and continued Medicaid coverage, these non cash benefits do not fit the description of a Supplemental Security income benefit.
Speaker B: Section: Speaker C:Double P double r double o double.
Speaker B:N double s double e double c.
Speaker C:Double t double I double o double.
Speaker B:N double s double e double c.
Speaker C:Double t double I double O double n double s double e double c double t double I double o double n double s double e double c double t double I double o double n double S double e double C double t double I double o double n double s double e double c double t double I double o double n double s double e double c double t double I double o double n double s double e double c double t double I double o double n double s double a double c double t double I double o double n double s double a double c double t double I double o double n double S double a double c double t double I double o double n double s double a double c double t double I double o double n double S S double a double c double t double I double o double n double s double a double c double t double I double o double n double s double a double c double t double I double o double n double S double a double c double t double I double o double n double s double a double c double Table I double O double n double S double a double c double TABLE O double n double s double a double c double t double I, double o double n double s double I, double c double t double I, double o I double o doublen double s double I double c double t double I double o doublen double s double e double c, double t double I double o double n double s double e double c double t double I double o double n double s double e double c double t double I double o double n double s double e double c double t double I double o double n double s double a double c double t double I double o double n double s double I, double c double t double I double o double n double s double a double c double c double t double I double o double n double s double e double c double t double I double o double n double s double e double c double t double I double o double n double s double e double c double t double I double o double n double s double e double c double t double I double o double n double s double e double c double t double I double o double n double s double e double c, double t I double o double n.
Speaker D:Double s double e double c double t double I double o doublen double s double e double c double t double I, double o double n double s double e double c, double t double I, double o double n double s double e double c double t double I double o double n double s double e double c double t double I double o double n double s double e double I double o double n double s double e double c double t double I, double o double n double s double e double c double t double I double o double n double s double e double c double t double I double o double n double s double e double c double t double I double o double n double s double e double c double t double I double o double n double s double e double c double t double I, double o double n a double s double e double c double t double I double o double n double s double t double I double o double n double s double e double c double t double I double o double n double s double e double c double t double I, double o double n double s double e double c double t double I double o double n double s double e double c double t double I, double o double n double s double e double c double t I double o doublen double s double e double c double t double c double t double I double o double n double s double e double c double t double I double o A double n double S double e double c double t double I double o double n double S double e double c double t double I double O double n double S double e double c double t double I double O double n double S double e double c double t double I double O double n double S double e double c double t double I double O double n double S double c double t double I double O double n double S double e double c double t double I double O double n double S double e double c double t double I double O double n double S double e double c double t double I double O double n double S double e double c double t double I double O double n double s Further, none of the non.
Speaker B:Cash benefits identified by the hospitals is.
Speaker C:Housed under subchapter 16 EBID emphasis added.
Speaker B:The hospital's reliance on the Ticket to Work and Self Sufficiency program falls short for this reason.
Speaker B:Nor do any of subchapter 16's other references to vocational rehabilitation services confer an SSI benefit.
Speaker B: Rather, Section: Speaker B: d coverage pursuant to section: Speaker B:In most states, eligibility for SSI benefits qualifies an individual for Medicaid coverage.
Speaker B: ing Medicaid coverage, section: Speaker B: But Section: Speaker B:Pages 9 to 112 the hospitals advance a second argument that eligibility for SSI benefits, even for purely cash benefits, begins when a person enters the SSI system and continues until the individual is ineligible for an SSI payment for 12 consecutive months.
Speaker B:While it is true that a person first applying for benefits must disclose her income rate for the calendar year, section 138 2A 11A that calendar year income does not render her eligible for SSI benefits, nor does it establish that SSI benefits operate in intervals with a duration longer than one month.
Speaker B:Instead, the statute clearly directs eligibility decisions to be made monthly based on the individual's income resources and other relevant characteristics in such month.
Speaker B: Section: Speaker B:A once eligible individual must submit a new application after she has been ineligible for benefits for a period of 12 consecutive months.
Speaker B:That provision does not state that a person remains eligible during this period.
Speaker B:It states that a person who was an eligible individual at one point must reapply after 12 consecutive months of ineligibility.
Speaker B: Section: Speaker B:Not so.
Speaker B:Just as Empire Health turned on the specific features of Medicare Part A, this case turns on the specific features of SSI benefits under subchapter 16.
Speaker B:Unlike Medicare Part A, which provides automatic ongoing health insurance that never goes away absent diminished disability.
Speaker B:Empire Health, 597 US at 437, SSI benefits require recipients to apply for and be deemed eligible for benefits, and recipients can and do fluctuate in and out of eligibility based on monthly income and resources.
Speaker B:Consistency with Empire Health's benefit focused analysis thus requires the Court to recognize and give effect to the differences between Medicare Part A and SSI benefits.
Speaker B:Pages 11 to 143 finally, invoking statutory purpose, the hospitals argue that their broad reading of entitled to SSI benefits better advances Congress's goal of providing additional funds to hospitals that serve a disproportionately high percentage of needy Medicare patients.
Speaker B:But no statute pursues a single policy at all Costs.
Speaker B:Barton Werfer vs Buckley, 598,981, and the court must respect the specific formula that Congress prescribed.
Speaker E: Pages: Speaker E:The majority's interpretation of Medicare's disproportionate share formula is based upon a fundamental misunderstanding of how SSI's cash benefit program works.
Speaker E:And that misunderstanding has led the majority to evaluate the Medicare statute without regard to the function of the formula's reference to the SSI program, causing it to reach the wrong conclusion.
Speaker E:To be specific, when Congress created Medicare's disproportionate share formula, it looked to SSI's cash benefits program for a reason.
Speaker E:No one disputes that Congress's ultimate goal was to provide hospitals that serve the neediest among us with the appropriate level of critical funds.
Speaker E:The only logical basis for the formula's reliance on ssi, then, is to draw from that program's pre existing pool of individuals that have already been designated as our society's neediest not to assess the wholly irrelevant fact of whether any such individual actually received a cash payment under the SSI program during the month of their hospitalization.
Speaker E:The majority's interpretation both ignores this critical context and endorses an interpretation of the Medicare formula that arbitrarily undercounts a hospital's low income patients.
Speaker E:In short, under the majority's reading, Congress's reference to the SSI scheme in the Medicare statute serves no rational purpose.
Speaker E:Worse still, the majority seems to think that a statutory formula specifically designed to authorize payments to certain hospitals in greater amounts is best read to affect the arbitrary denial of those additional funds.
Speaker E:Respectfully, I.
Speaker A:Dissent CASE Implications Several real world implications may emerge from this opinion.
Speaker A:First, hospitals serving low income populations could face reduced Medicare reimbursements since the Court's interpretation excludes from the Medicare fraction those patients who are enrolled in SSI but don't receive a payment in their month of hospitalization, potentially leading some financially stressed hospitals to reduce services or close entirely.
Speaker A:Second, the ruling might disproportionately impact hospitals in areas with seasonal employment or irregular work patterns, where patients monthly income fluctuations could affect their SSI payment status and thus the hospital's DSH adjustment calculations.
Speaker A:Third, this interpretation could create administrative challenges for hospitals trying to predict their DSH payments, as monthly SSI payment status may be harder to track than simple program enrollment status.
Speaker A:Fourth, as Justice Jackson suggests in her dissent, Congress may need to revisit and clarify the statutory language to ensure the DSH program fulfills its intended purpose of adequately supporting hospitals that serve higher proportions of low income patients.
