Advocate Christ Medical Center v. Kennedy (No. 23-715)
Summary
The Supreme Court case Advocate Christ Medical Center v. Kennedy (No. 23-715) concerns the calculation of the Medicare fraction used to determine disproportionate share hospital (DSH) adjustments. These adjustments provide additional funding to hospitals that treat a high percentage of low-income patients. The central issue is the interpretation of "entitled to supplementary security income benefits" under subchapter XVI of the Social Security Act, specifically whether it includes all patients enrolled in the SSI system or only those receiving SSI payments during their month of hospitalization.
Expected Effects
The Supreme Court affirmed the D.C. Circuit's decision, holding that an individual is "entitled to SSI benefits" for purposes of the Medicare fraction only when they are eligible to receive an SSI cash payment during the month of their hospitalization. This ruling will likely result in reduced DSH payments to some hospitals, as fewer patients will be counted in the Medicare fraction's numerator.
Potential Benefits
- Potentially more accurate targeting of DSH funds to hospitals serving patients with immediate, demonstrated need.
- Greater clarity and consistency in the application of the Medicare fraction formula.
- Reduced administrative complexity for HHS by relying on readily available payment data.
- Upholding the specific statutory language chosen by Congress, respecting the separation of powers.
- Discourages hospitals from potentially manipulating patient status to maximize DSH payments.
Most Benefited Areas:
Potential Disadvantages
- Potential reduction in funding for hospitals that serve a significant number of low-income patients who may not always receive SSI payments due to fluctuating income.
- May not fully capture the financial burden on hospitals treating patients who are temporarily ineligible for SSI but still face significant economic hardship.
- Increased financial strain on hospitals serving vulnerable populations, potentially leading to reduced services or closures.
- Disproportionate impact on hospitals in areas with high rates of poverty and reliance on SSI benefits.
- Could incentivize hospitals to prioritize patients who are currently receiving SSI payments, potentially neglecting others in need.
Constitutional Alignment
The case primarily involves statutory interpretation of the Social Security Act and its interaction with the Medicare program, both established under the authority granted to Congress to provide for the general welfare (Article I, Section 8). The Court's role is to interpret the law as written by Congress, respecting the separation of powers. The dissenting opinion argues that the majority's interpretation undermines the intent of Congress to support hospitals serving low-income patients.
Impact Assessment: Things You Care About ⓘ
This action has been evaluated across 19 key areas that matter to you. Scores range from 1 (highly disadvantageous) to 5 (highly beneficial).