Atkins v. RiveraAtkins v. Rivera
delivered the opinion of the Court.
This case concerns the means by which a State may calculate eligibility for medical-assistance benefits (Medicaid) under Title XIX of the Social Security Act.
In Massachusetts, persons who lack sufficient income, measured on a monthly basis, to meet their basic needs automatically qualify for Medicaid. The Commonwealth, however, also provides Medicaid benefits to persons, like respondents, who еarn enough to meet their basic needs, but whose medical expenses within a 6-month period consume the amount by which their earnings exceed what is required for basic needs. Construing the Act’s requirement that assistance for the two groups be calculated using the "same methodology,” the Massachusetts Supreme Judicial Court held invalid the Commonwealth’s use of a 6-month period for measuring medical expenses. Thе court ruled that inasmuch as a 1-month period is used to measure the income of those with insufficient means, an identical period must be used to measure medical expenses for persons like respondents. Because this holding conflicts with rulings of two Federal Courts of Appeals,
1
we granted certiorari.
I
Medicaid, enacted in 1965 as Title XIX of the Social Security Act, 79 Stat. 343, as amended,
States participating in the Medicaid program must provide coverage to the “categorically needy.”
A participating State also may elect to provide medical benefits to the “medically needy,” that is, persons who meet the nonfinancial eligibility requirements for cash assistance under AFDC or SSI, but whose income or resources exceed the financial eligibility standards of those programs.
3
See
In creating the spenddown mechanism. of
A State electing to assist the medically needy must determine eligibility under standards that are “reasonable” and “comparable for all groups.”
“the single standard to be employed in determining income and resource eligibility for all such groups, and the methodology to be employed in determining such eligibility which shall be the same methodology which would be employed under [AFDC or SSI].”42 U. S. C. § 1396a(a)(10)(C)(i)(III) (emphasis added).
Respondent Rivera is employed outside her home and is the mother of two children. She receives no medical benefits from her job, and earns an amount slightly in excess of that which would permit her to qualify for AFDC. In 1983, Rivera applied to the Massachusetts Department of Public Welfare for Medicaid. Massachusetts has chosen to participate in the Medicaid program, Mass. Gen. Laws § 118E:1 et seq. (1984), and also to provide coverage to medically needy persоns.
To determine Rivera’s eligibility for Medicaid, the Department first calculated her gross monthly income. See 106 Code of Mass. Regs. (CMR) §§505.200, 505.210, 505.320 (1985). Next, the Department prescribed certain deductions and disregards to arrive at her monthly “countable income” of $535.30.
4
See 106 CMR §§505.200 and 506.100-506.200 (1985). See also
Massachusetts has adopted a 6-month period over which the spenddown is calculated. Mass. Gen. Laws §118E:10 (1984); 106 CMR §§506.400 and 506.510 (1985). This is the maximum permitted under the federal regulations. See
Rivera then sought injunctive relief in State Superior Court against use of the 6-month period. She argued that the 6-month period for calculating the income of medically needy applicants violates the “same methodology” requirement of
The court certified a class of all persons who have been, are bеing, or will be subjected to the Department’s 6-month spenddown requirement. On a motion for summary judgment, the court found that the Department’s use of the 6-month spenddown period violated the statutory requirement that the “same methodology” be used for determining eligibility of the medically needy as is used for the categorically needy. App. to Pet. for Cert. A28.
The Department appealed to the Massachusetts Supremе Judicial Court. It argued there that, since the eligibility determination for the categorically needy does not involve a spenddown at all, there is no methodology for the Department to match. The Department further argued that federal regulations explicitly allow a 6-month period.
I — I >■ — I l-H
Congress created the spenddown provision in 1965 to eliminate a perceived weakness in the medical-assistance program then in effect. See Social Security Amendments of 1960,
To cure this problem, the Medicaid statute was amended to requirе state eligibility standards to measure income in terms of both the State’s allowance for basic maintenance needs
and
the cost of the medical care required. The standards applied to the medically needy are to be “reasonable”
Pursuant to this authority, the Secretary has provided, from the inception of Medicaid until the present time, that States may employ a maximum spenddown period of six months. See
IV
A
Respondents contend that the Secretary’s regulation, and Massachusetts’ 6-month spenddown enacted pursuant thereto, are “manifestly contrary to the statute.” Respondents point to another section of the Act,
B
The history of the “same methodology” proviso, which first appeared in the Act in 1981, demonstrates that it was never intended to control the length of the spenddown. Rather, the “same methodology” requirement simply instructs States to treat components of income — e. g., interest or court-ordered support payments — similarly for both medically and categorically needy persons.
The “same methodology” proviso was nоt Congress’ first attempt to regulate the relationship between treatment of the categorically needy and treatment of the medically needy. To understand the precise purpose of the “same methodology” proviso requires a brief foray into Congress’ earlier efforts to address this relationship, for the proviso reflects Congress’ desire to overrule a particular interpretation that had been advanced by the Secretary.
When Medicaid was first enacted, Congress did not require that the “same methodology” be used for determining the eligibility of categorically and medically needy individuals. Instead, it required only that a State’s Medicaid plan use
Congress concluded that the administrative and judicial interpretation of the “comparability” provision denied States necessary flexibility to set eligibility standards and to adjust the scope of services to fit the varying requirements of medically needy persons. See H. R. Rеp. No. 97-208, p. 971 (1981). Thus, as part of the Omnibus Budget Reconciliation Act of 1981 (OBRA), 95 Stat. 357, Congress amended the
The Secretary interpreted OBRA to authorize States to use income and resоurce criteria for medically needy different from those for categorically needy individuals:
“States are no longer required to apply a uniform methodology for treating income and resources in such matters as deemed income, interest, court-ordered support payments, and infrequent and irregular income. Rather, the State plan must specify the methodology that will be used, and that methodology must be reasonable.” 46 Fed. Reg. 47980 (1981).
The regulations promulgated by the Secretary accordingly left the States free to use eligibility standards that were unrelated to the standards used in AFDC or SSI, as long as the standards were “reasonable.”
9
The Secretary’s regulations did not address treatment of excess income for the medically needy or the calculation of spenddowns. Despite the various changes that follоwed OBRA’s passage, many States contin
Congress disagreed with the Secretary’s interpretation. See, e. g., 127 Cong. Rec. 23363 (1981) (remarks of Rep. Wax-man). This disagreement led to the enactment of the “same methodology” proviso, as part of the Tax Equity and. Fiscal Responsibility Act of 1982 (TEFRA), § 137(a)(8), 96 Stat. 378. The House Report explained that TEFRA “makes clear that the Department [of Health and Human Services] had no authority to alter the rules that applied before September 30, 1981, with respect to medically needy income levels, medically needy resource standards, and the methodology for treating medically needy income and resources.” H. R. Rep. No. 97-757, pt. 1, p. 13 (1982). The House Report further explained that TEFRA reaffirmed “the financial requiremеnts previously in effect for the medically needy.” Ibid.
Thus, the “same methodology” proviso was designed to correct a problem wholly unrelated to the 6-month spend-down, which had remained in force from the inception of Medicaid. The proviso operated solely to invalidate the post-OBRA regulations permitting the income and resource standards in state Medicaid plans to deviate from those used in the AFDC and SSI programs in “such matters as deemed income, interest, court-ordered support payments, and infrequent and irregular income.” See 46 Fed. Reg. 47980 (1981). Treatment of excess income and the calculation of spenddowns were left untouched by the “same methodology” proviso. 10
The Medicaid Act itself is silent as to how-many months’ excess income the State may require an individual or a family to contribute tо medical expenses before Medicaid coverage of further medical expenses begins. The Secretary’s interpretation of the Act is consistent with congressional intent, and under that interpretation Massachusetts is free to choose a 6-month spenddown. Accordingly, the judgment of the Supreme Judicial Court is reversed.
It is so ordered.
Notes
See
Hogan
v.
Heckler,
Congress created SSI in 1972, 86 Stаt. 1465, to replace three existing categorical assistance programs — Old Age Assistance,
In Massachusetts, the income eligibility level for the medically needy is comparable in most, but not all, instances to the corresponding SSI or
In administrative and state-court proceedings, Rivera raised a challenge to the manner in which certain portions of her income were disregarded. That issue, however, is not presently before this Court.
The spenddown may be satisfied by submission of paid or unpaid medical bills. 106 CMR § 506.540 (1985).
Respondent Madeline McKenna was permitted to intervene in the Superior Court proceedings. McKenna, like Rivera, was denied Medicaid. McKenna’s monthly countable income was calculated to be $531.66, which is $106.66 in excess of the $425 eligibility standard for a family оf two. Thus, McKenna could receive medical assistance only after incurring medical expenses of $639.96 in a 6-month period.
The 1965 legislation was to the effect that a State choosing to extend assistance to the medically needy provide “for making medical or remedial care and services available to all individuals who would, if needy, be eligible for aid or assistance under any. . . State [cash assistance program] and who have insufficient (as determined in accordance with comparable standards) income and resources to meet the costs of necessary medical or remedial care and services.” 79 Stat. 345.
The current version of the Act also contains a “comparability” requirement. See §
The Secretary further explained:
“Before the 1981 Amendments, the methodology for treatment of income and resources of the medically needy depended on the individual’s relationship tо a specific cash assistance program. For example, the methodology for deeming the income of medically needy aged, blind, and disabled was taken from the SSI program. . . . [T]he 1981 Amendments revised the Medicaid statute so that the direct linkage between the cash assistance programs and the medically needy is no longer explicit. . . . Therefore, we have concluded that the State need not adopt the methodology of a related cash assistance program in treating income and resources of the medically needy. Rather, the State may develop its own. However, section 1902(a)(17)(C) of the Act has not been amended. Consequently, these final regulations require that the State must use a methodology for the treatment of income and resources that is reasonable.” 46 Fed. Reg. 47980 (1981).
Subsequеnt legislative history is to the same effect and makes clear that TEFRA did not address the length of the spenddown. In the Deficit Reduction Act of 1984, § 2373(c)(1), 98 Stat. 1112, Congress amended