605 U.S. 1
SCOTUS2025Background
- Medicare reimburses hospitals using a formula that provides extra funds to hospitals that serve many low-income patients, known as the Disproportionate Share Hospital (DSH) adjustment.
- The DSH formula includes a “Medicare fraction,” which counts patient days for Medicare patients who are also "entitled to Supplemental Security Income (SSI) benefits" under subchapter XVI.
- The statutory phrase “entitled to [SSI] benefits” is not expressly defined as to whether this means all SSI enrollees or only those eligible for a cash payment in the specific month of hospital care.
- The Department of Health and Human Services (HHS) interprets this to include only patients eligible for an SSI cash payment in the hospital month; a group of over 200 hospitals sued, claiming the formula undercounts low-income patients and results in underpayment.
- Lower courts (including the D.C. Circuit) sided with HHS, finding the agency’s interpretation consistent with the statute’s focus on cash payments and monthly eligibility.
- The Supreme Court granted certiorari to resolve the interpretive dispute and affirmed the lower court’s judgment, holding that “entitled to [SSI] benefits” refers only to months when the patient was eligible for an SSI cash payment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning of “entitled to [SSI] benefits” in the DSH formula | Includes all enrolled SSI patients during hospitalization, regardless of payment that month | Only patients eligible for an SSI cash payment during the hospital month are counted | Only those eligible for an SSI cash payment that month are "entitled" to SSI benefits |
| Inclusion of non-cash SSI benefits | SSI includes non-cash benefits (e.g., Medicaid, vocational rehab); these should count | Only cash benefits under subchapter XVI count for the formula | Only cash SSI payments under subchapter XVI count |
| Annual vs. monthly eligibility for SSI | SSI eligibility is annual (not just monthly), so patients should be counted if generally eligible | SSI eligibility and payments are determined monthly by statute | SSI entitlement is determined monthly |
| Statutory purpose and rationality | Broader reading to further Congress’s intent to help hospitals serving low-income patients | Congress chose a specific, administrable formula based on monthly eligibility | Court must apply Congress’s chosen formula, not rewrite the statute |
Key Cases Cited
- United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (discussing the non-binding nature of the syllabus)
- Becerra v. Empire Health Foundation, for Valley Hospital Medical Center, 597 U.S. 424 (addressing the interpretation of “entitled to [Medicare Part A] benefits” in the DSH context; relevance of benefit program characteristics)
- Sebelius v. Auburn Regional Medical Center, 568 U.S. 145 (explains DSH payment adjustments for hospitals serving low-income patients)
- Schweiker v. Wilson, 450 U.S. 221 (describes the purpose of SSI as a subsistence allowance for the needy)
- Bowen v. Galbreath, 485 U.S. 74 (confirms SSI is a welfare program)
- Bartenwerfer v. Buckley, 598 U.S. 69 (court must respect statutory choices rather than policy preferences)
- Luna Perez v. Sturgis Public Schools, 598 U.S. 142 (statutory construction—no statute serves one purpose at all costs)
- Kucana v. Holder, 558 U.S. 233 (purpose does not override statutory text)
- Rodriguez v. United States, 480 U.S 522 (per curiam) (emphasizes legislative compromise over single policy enforcement)
