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Becerra v. Empire Health Foundation, For Valley Hospital Medical Center
597 U.S. 424
SCOTUS
2022
Read the full case

Background:

  • Medicare Part A entitlement is automatic at age 65 or after 24 months of SSDI; Part A covers inpatient hospital care.
  • The Disproportionate Share Hospital (DSH) adjustment increases Medicare payments based on two fractions: the Medicare fraction (share of patient-days that are Medicare beneficiaries who receive SSI) and the Medicaid fraction (share of patient-days that are non-Medicare patients eligible for Medicaid).
  • The Medicare-fraction statutory text counts patient days "for such days" attributable to patients "entitled to benefits under part A," prompting dispute over whether "entitled" requires Medicare to have paid for that day.
  • A 2004 HHS regulation treats "entitled to Part A benefits" as meaning anyone who qualifies for Part A (age/disability), regardless of whether Medicare actually paid for particular hospital days.
  • Empire Health Foundation challenged the regulation; the Ninth Circuit sided with Empire (reading "entitled" to mean actual payment entitlement), conflicting with the Sixth and D.C. Circuits that upheld HHS; the Supreme Court granted certiorari.
  • The Supreme Court reversed the Ninth Circuit, holding that "entitled to benefits" means qualifying for Part A irrespective of whether Medicare paid for specific hospital days; the parenthetical "(for such days)" only limits counting to days after entitlement begins (e.g., after turning 65), not to days Medicare paid.

Issues:

Issue Plaintiff's Argument (Empire) Defendant's Argument (HHS/Becerra) Held
Whether "entitled to benefits under Part A" requires Medicare to have actually paid for the patient-day "Entitled" means an absolute right to payment for that day; exclude days Medicare did not pay "Entitled" is a term of art in the Medicare statute meaning qualification (age/disability), regardless of payment Court: "Entitled" means qualifying for Part A; payment status is irrelevant
Effect of the parenthetical "(for such days)" The parenthetical narrows "entitled" to days Medicare actually paid It only requires counting days on which the person met entitlement criteria (e.g., post-65), not actual payment days Court: Parenthetical limits counting to days after entitlement begins but does not convert "entitled" into "paid for"

Key Cases Cited

  • Sebelius v. Auburn Reg'l Med. Ctr., 568 U.S. 145 (2013) (discusses DSH adjustment purpose)
  • Bowen v. Galbreath, 485 U.S. 74 (1988) (characterizes SSI as benefits for financially needy individuals)
  • Metropolitan Hosp. v. Dep't of Health & Human Servs., 712 F.3d 248 (6th Cir. 2013) (upheld HHS regulation counting qualifiers)
  • Catholic Health Initiatives Iowa Corp. v. Sebelius, 718 F.3d 914 (D.C. Cir. 2013) (upheld HHS interpretation)
  • Northeast Hosp. Corp. v. Sebelius, 657 F.3d 1 (D.C. Cir. 2011) (analysis of "entitled"/"eligible" usage across statutes)
  • Whitman v. American Trucking Ass'ns, 531 U.S. 457 (2001) (canon against inferring major changes from ancillary or parenthetical language)
Read the full case

Case Details

Case Name: Becerra v. Empire Health Foundation, For Valley Hospital Medical Center
Court Name: Supreme Court of the United States
Date Published: Jun 24, 2022
Citation: 597 U.S. 424
Docket Number: 20-1312
Court Abbreviation: SCOTUS