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605 U.S. 1
SCOTUS
2025
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Background

  • 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)
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Case Details

Case Name: Advocate Christ Medical Center v. Kennedy
Court Name: Supreme Court of the United States
Date Published: Apr 29, 2025
Citations: 605 U.S. 1; 145 S.Ct. 1262; 23-715
Docket Number: 23-715
Court Abbreviation: SCOTUS
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    Advocate Christ Medical Center v. Kennedy, 605 U.S. 1