Medicaid

Issues

Medicaid provides certain needy individuals with funds for medical treatment. The program is administered by the states with federal funding and statutory guidelines. Federal Medicaid law generally forbids states from placing liens on the "pre-death" property of Medicaid beneficiaries. The Arkansas Medicaid program requires beneficiaries to sign over their interest in any future legal claim before receiving benefits. Technically, this case will decide whether the federal statutes prohibit states from doing this. More importantly, the decision will determine to what extent states can recoup Medicare expenses from private tort judgments and settlements, and could have a profound effect on how the costs of the Medicaid are distributed between the states and private parties.

Questions as Framed for the Court by the Parties

Issues

This case asks the Supreme Court to grant a stay of a district court injunction that currently blocks the Biden Administration from enforcing a mandate requiring certain healthcare workers to be fully vaccinated against COVID-19. The Biden Administration argues that the Supreme Court should issue a stay because the mandate is statutorily authorized, and its enforcement is in the public interest. The State of Missouri and nine other states (collectively “Missouri”) counter that the Supreme Court should reject the Biden Administration’s application for a stay and maintain enjoinment of the mandate throughout the pending litigation. The outcome of this case has significant implications for the Biden Administration’s pandemic-related authority and the role that the Supreme Court will play in either upholding or invalidating such authority.

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E.M.A., a minor, suffered catastrophic injuries during her birth due to the physician's negligence during delivery. As part of its Medicaid program, North Carolina paid for E.M.A.’s medical expenses upon her mother’s agreement to reimburse the Medicaid program for any recovery gained from a third party to cover E.M.A.’s medical expenses. When E.M.A. settled her claim against the physician for a fraction of her medical costs, North Carolina attached a lien equal to one third of the total settlement. In this case, the Supreme Court will resolve a conflict between the North Carolina Supreme Court and the United States Court of Appeals for the Fourth Circuit.  The Court will decide whether a North Carolina law that allows the North Carolina Department of Health and Human Services (“DHHS”) to assert a lien against a Medicaid recipient's recovery from a third party, when limited to the lesser of either the total amount of medical expenses or one third of the Medicaid recipient’s total settlement amount, violates the "no-lien" provision of the Medicaid Act. DHHS argues that the North Carolina statute is consistent with the Medicaid Act’s no-lien provision because it operates as an advanced agreement to apportion one third of the settlement toward medical expenses.  E.M.A. responds that the statute violates the Medicaid Act because it allows DHHS to recover a proportion of the settlement that is greater than her medical expenses.  This case will allow the Court to balance the interest that States have in maintaining solvent Medicaid programs against the interests of Medicaid claimants who fail to recover sufficient damages from third-parties to cover their medical costs.

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Issues

A series of reforms passed by the California Assembly in 2008 and 2009 reduced the state’s payments made to California Medicaid providers. Respondents Independent Living Center of Southern California, the California Pharmacists Association, and Santa Rosa Memorial Hospital brought suit in the U.S. District Court for the Central District of California, claiming that the payment reductions violated 42 U.S.C. § 1396a(a)(30)(A), which requires that state Medicaid plans comply with federal law or lose federal funding. Petitioner Toby Douglas, the Director of the Department of Health Care Services for the State of California, argues that health care providers cannot sue to enforce § 30(A) because the statute does not grant any enforceable rights, and Congress did not intend for private parties to sue to enforce the statute. Conversely, the health care providers argue that the Supremacy Clause permits private parties to sue if they have suffered an injury from state action, and they assert that Congress did not explicitly disallow private lawsuits in § 30(A). The Supreme Court’s decision will affect the predictability of federal law, the ability of private parties to bring lawsuits to enforce federal law, and the availability of health care to Medicaid beneficiaries.

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Issues

This case asks the Supreme Court to determine whether, pursuant to the federal Medicaid Act, a state Medicaid program may recover reimbursement for its payment of a beneficiary’s past medical expenses by allocating funds from a portion of the participant’s settlement that compensates for future medical expenses. Florida law requires Medicaid beneficiaries to assign any rights to reimbursement for medical care from third parties to the state. In this case, Gianinna Gallardo contends that a state cannot collect reimbursement for future medical expenses from a Medicaid beneficiary’s settlement against a third party. In response, Simone Marstiller, Secretary of the Florida Agency for Health Care Administration, counters that the state may recover reimbursement for both past and future medical expenses because the Florida statute does not explicitly bar recovery for future medical care. The outcome of this case will affect how the burden of Medicaid costs is allocated between individuals and the state and federal governments.

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Issues

This case asks the Court to determine when an individual, private right is enforceable under 42 U.S.C. § 1983. South Carolina’s executive order deems abortion clinics enrolled in the Medicaid program as unqualified to provide family planning services. Planned Parenthood South Atlantic and its patient, Julie Edwards, contend that the executive order violates Ms. Edwards’s right to choose a qualified provider under 42 U.S.C. § 1396a(a)(23), the any-qualified-provider provision. South Carolina counters that the any-qualified-provider fails to create a private right of action enforceable through § 1983 because Congress did not use unambiguously clear rights-creating language. The outcome of this case has heavy implications for Medicaid beneficiaries and providers, the implementation of state and federal healthcare policy goals, and the litigation of private rights. 

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