Today, the Supreme Court of the United States (SCOTUS) affirmed the D.C. Circuit’s decision in Advocate Christ Medical Center v. Secretary of Health and Human Services by a 7-2 vote, with Justices Jackson and Sotomayor dissenting.
In the majority opinion, the Court stated:
“For purposes of the Medicare fraction, an individual is entitled to [SSI] benefits when she is eligible to receive an SSI cash payment during the month of her hospitalization. §1395ww(d)(5)(F)(vi)(I). We must respect the formula that Congress prescribed. [...] For the foregoing reasons, we affirm the judgment of the Court of Appeals.”
While the Court must weigh many legal and statutory considerations, the outcome—particularly when viewed in tandem with the Empire ruling and the final interpretation of Medicaid days—presents a confusing landscape to the lay observer.
In particular, the term “entitled” is potentially interpreted inconsistently within the same statute. For Medicare Part A, being “entitled” does not require a beneficiary to receive benefits, a point clarified in Empire. However, in the context of Supplemental Security Income (SSI), the Court now interprets “entitled” to mean that benefits must be received—not just eligibility established. Meanwhile, Medicaid days have long been evaluated based on “eligibility” alone, aligning more with the Part A interpretation of “entitled”.
Taken together, the Advocate, Empire, and original Allina rulings largely resolve a decades-long legal battle concerning Medicare DSH—ultimately siding with the government and curbing reimbursement amounts for safety-net hospitals. Yet not all issues are settled: offshoot cases from Allina remain pending before the Provider Reimbursement Review Board (PRRB) and continue to surface in other courts under different legal theories.
