Advocate Christ Medical Center v. Kennedy

An individual is “entitled to [SSI] benefits” under subchapter XVI for purposes of the Medicare fraction only if the person is eligible to receive a cash payment during the month of their hospitalization. Justice Amy Coney Barrett authored the 7-2 majority opinion of the Court, joined by Chief Justice John Roberts and Justices Clarence Thomas, Samuel Alito, Elena Kagan, Neil Gorsuch, and Brett Kavanaugh. Congress designed the Medicare Disproportionate Share Hospital (DSH) adjustment to provide extra funding to hospitals treating a large number of low-income patients. This adjustment is partly determined using the “Medicare fraction,” which measures the proportion of Medicare patients who also qualify for Supplemental Security Income (SSI). The statutory language refers to patients “entitled to [SSI] benefits under subchapter XVI.” The Court interpreted this to mean patients who are actually eligible to receive an SSI cash payment during the hospital stay month. This interpretation followed from several provisions in subchapter XVI demonstrating that SSI consists solely of monthly cash payments and eligibility is determined month by month. Terms such as “paid” and “payable” and monthly income evaluations underscore that SSI benefits are defined as monthly cash entitlements, not continuous enrollment in the program regardless of payment status. The Court found alternative arguments offered by the hospitals unpersuasive. Non-cash programs like vocational rehabilitation or Medicaid continuation are not SSI benefits under subchapter XVI; they either reside in other statutory subchapters or administer distinct programs. The Court also dismissed the view that finding a person ineligible for SSI for 12 continuous months is what marks the end of entitlement. While administrative statutes may require re-application after 12 months of ineligibility, SSI eligibility still depends on month-by-month financial qualification. Finally, the Court declined to broaden the statutory intent to optimize funding for needy hospitals beyond the method Congress explicitly chose. Having determined that entitlement is tied to monthly cash payment eligibility, the Court upheld HHS’s method of calculating the Medicare fraction accordingly. Justice Ketanji Brown Jackson authored a dissenting opinion, in which Justice Sonia Sotomayor joined.