decided April 29, 2025
The lengthy statute that governs the federal Medicare program contains an obscure formula for calculating enhanced Medicare payments to hospitals for treating a “disproportionate” number of patients who receive “income benefits” under the federal government’s separate Supplemental Security Income {“SSI”) program. See 42 U.S.C. §1395ww(d)(5)(F)(vi)(I). The enhancement formula requires, among other things, the counting of “patient days” spent at the hospital by patients “entitled to supplementary security income benefits.” Ibid.
In this case, the Court ruled 7-2 that the “patient day” count required by enhancement formula had to be limited to the number of SSI “patient days” spent during months in which the SSI “patient” beneficiary actually received payment of the SSI “income benefit.” “Patient days” spent during months in which the SSI beneficiary received no SSI payments had to be excluded from the enhancement formula’s count, thereby lowering the amount of the enhancement otherwise payable to the hospital. The Court explained that this reduction was required by the intended meaning of the statute’s words “income benefits” as covering only the actual payment of “income benefits to the SSI beneficiary during the current month.
Justices Jackson and Sotomayor dissented from the Court’s ruling. They argued that the words “income benefits” meant more than the actual payment of SSI benefits but also included the benefit of the guaranteed annual income, regardless of its source, promised to eligible participants in the SSI program.
Comment: The dissent’s interpretation of the enhancement formula specified by 42 U.S.C. §1395ww(d)(5)(F)(vi)(I) better serves the intent and purpose of that short statutory subsection. There, Congress intended to reward hospitals that serve “disproportionate” numbers of poor patients (receiving SSI benefits), to cover the extra costs hospitals incur in serving that population. The term “income benefits” can semantically refer either to actual monthly payments of SSI funds to SSI beneficiaries, or to the minimum annual income guaranteed to SSI beneficiaries by the SSI program, regardless of occasional non-payment of monthly benefits. The term “income benefits” in the subsection is therefore ambiguous. When the words of a statute are ambiguous, but their intent and purpose are otherwise clear, that intent and purpose should control the Court’s resolution of the ambiguity.
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