Advocate Christ Medical Center v. Becerra
Issues
Are patients “entitled to” SSI benefits when they are eligible for SSI benefits or when they are receiving cash SSI benefits?
The Disproportionate Share Hospital adjustment (“DSH”) is a statutory provision administered by the Centers for Medicare & Medicaid Services (“CMS”) within the Department of Health and Human Services (“HHS”) that increases payments to hospitals serving high percentages of low-income patients to account for their increased treatment costs. At issue here is how eligibility for Supplemental Security Income (“SSI”) affects these DSH payments. Advocate Christ Medical Center argues that the phrase “entitled to [SSI] benefits” in the DSH provision should include all patients enrolled in the SSI program, even if they do not receive monthly cash payments. HHS counters that only patients receiving cash benefits during hospitalization should count. This case has important ramifications on agency interpretation, administrative workability, and hospitals’ ability to accept low-income patients.
Questions as Framed for the Court by the Parties
Whether the phrase “entitled ... to benefits,” used twice in the same sentence of the Medicare Act, means the same thing for Medicare part A and Supplemental Social Security benefits, such that it includes all who meet basic program eligibility criteria, whether or not benefits are actually received.
Administered by the Centers for Medicare & Medicaid Services (“CMS”) within the Department of Health and Human Services (“HHS”), the Medicare program aims to provide health insurance to elderly or disabled individuals. Advocate Christ Med. Ctr. v. Becerra at 349, 351. Hospitals receive a fixed payment for treating a Medicare patient. Id. At 349.
Additional Resources
- Stephanie Webster, Beth Weinman, and Pascale Stain, Litigation, Professional Perspective - Implications of Loper Bright & Relentless for HHS-Regulated Entities, Bloomberg Law (May 2024).
- Leonard Lipsky, John Herbstritt, Alexandria Foster & Christian Corrales, SCOTUS to Review Case Impacting Medicare Reimbursement for Hospitals Treating Low-Income Patients, The National Law Review (July 2, 2024).
- Cathleen Calhoun, Supreme Court to decide multiple health law questions beginning in October, Wolters Kluwer (September 12, 2024).