Ciampa v. Secretary of Health & Human Services

687 F.2d 518
CourtCourt of Appeals for the First Circuit
DecidedAugust 27, 1982
DocketNos. 82-1145, 82-1175
StatusPublished
Cited by4 cases

This text of 687 F.2d 518 (Ciampa v. Secretary of Health & Human Services) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ciampa v. Secretary of Health & Human Services, 687 F.2d 518 (1st Cir. 1982).

Opinion

BREYER, Circuit Judge.

This case involves interpreting the highly technical (and aptly named) “Pickle Amendment” to the Social Security Act, 42 U.S.C. § 1396a (note). This amendment restores Medicaid benefits to certain persons who at one time received both Supplementary Security Income (“SSI”) and Old Age Survivors and Disability Insurance (“OASDI”). The appellants, state and federal governments, claim that these certain persons include only those whom an OASDI cost-of-living increase would otherwise cause to lose the Medicaid benefits. The appellees, a class of social security recipients, claim that the amendment also covers those who would qualify for the Medicaid benefits but for the OASDI cost-of-living increase. In essence, we are asked to decide whether the Pickle Amendment uses a “but for” test or a narrower test of “causation” in selecting its beneficiaries. And our decision will determine whether appellees, and others in their class, receive the more generous Medicaid benefits given to SSI recipients, or the less generous Medicaid benefits available to those who do not receive SSI. The district [520]*520court, 511 F.Supp. 670 decided that the appellees’ interpretation of the statute was correct. We agree.

I

To begin to understand this case, one must first have in mind the basic functions of the three government programs at issue. SSI, 42 U.S.C. § 1381 et seq., is a government assistance program of last resort. It helps the aged, blind and disabled poor. The federal government administers the program, paying each covered person enough money to bring his income up to “minimum” level. This “minimum” equals at least a nationally uniform, federally determined level. If a state is willing to pay the added cost, this “minimum” may be set higher. In Massachusetts, for example, the SSI minimum equals the federal minimum plus certain “optional state supplements” that the law allows. See 42 U.S.C. § 1382e; Constance v. Secretary of Health & Human Services, 672 F.2d 990, 991-92 (1st Cir. 1982).

OASDI, 42 U.S.C. § 401 et seq., is what is popularly known as “Social Security.” It provides workers (or their families) cash payments when they retire, become disabled, or die. Mathews v. DeCastro, 429 U.S. 181, 185-86, 97 S.Ct. 431, 434-435, 50 L.Ed.2d 389 (1976). It is primarily an insurance program. Thus, the amount of payment depends in part upon how much a covered worker and his employers have previously paid into the system.

Medicaid, 42 U.S.C. § 1396 et seq., is a federal program that reimburses states for providing medical care to those who cannot afford it. See generally Harris v. McRae, 448 U.S. 297, 301, 100 S.Ct. 2671, 2680, 65 L.Ed.2d 784 (1980); Preterm v. Dukakis, 591 F.2d 121 (1st Cir.), cert. denied, 441 U.S. 952, 99 S.Ct. 2182, 60 L.Ed.2d 1057 (1979). For purposes of this case its most important feature is that anyone who qualifies for SSI automatically qualifies for Medicaid. 42 U.S.C. § 1396a(a)(10)(A). Cf. id. § 1396a(a)(10)(C); Schweiker v. Hogan, - U.S. -, - & n.19, 102 S.Ct. 2597, 2606 & n.19, 73 L.Ed.2d 227 (1982). But one who does not qualify for SSI (with certain exceptions not relevant here) does not qualify for Medicaid unless he is “medically needy” — i.e. unless his medical expenses are so great that his remaining income would be no more than four-thirds of the amount that would qualify him for state welfare assistance (under Aid to Families with Dependent Children, 42 U.S.C. § 601 et seq.). See 42 U.S.C. §§ 1396a(a)(10)(C), 1396b(f) (1). Leaving aside the technicalities, a person who qualifies to receive even one penny of SSI will automatically receive Medicaid benefits; should he fail to qualify for SSI, however, by even one penny, he will not receive Medicaid unless he runs up fairly significant medical bills. That fact lies at the heart of this case.

These different aid programs interact in other ways directly relevant to the case at hand. For one thing, a person can receive both OASDI and SSI. This could happen where a person’s OASDI, which depends in part upon prior “contributions,” is less than the eligibility level for SSI. It could also happen where the applicable SSI “minimum” includes an “optional state supplementary payment” sufficient to raise the SSI threshold above the level of OASDI. The situation of the Ciampas in November 1978 illustrates the point. They were entitled to receive $462.61 per month in SSI (consisting of both a federal and a state payment); they received $440.30 in OASDI; so, if they had received no other income, and if all their OASDI “counted” when it came to computing SSI, the Ciampas would have been entitled to $22.31 in SSI — the amount needed to bring their income up to the SSI “minimum.” (Because they did receive other income, and because not all of their income “counted” in the SSI calculation, see p. 9, infra, the Ciampas in fact received a different amount of SSI.)

In fact, a person might be eligible for SSI even if his income is a little higher than the “minimum.” This is so because some income is “disregarded” — or not counted — for purposes of calculating SSI. The mpst important “disregard” for our purposes is the general “$20 disregard” — the provision that [521]*521says $20 per month of outside income will be ignored in calculating eligibility for, and the amount of, SSI. 42 U.S.C. § 1382a(b)(2)(A). Thus, if the SSI “minimum” were $462.61, the Ciampas would be eligible for some SSI payment as long as their outside income was less than $482.61 per month, for $20 of that outside income would be disregarded.

For another thing, both OASDI and SSI payment levels rise each year to take account of inflation. The OASDI payment (which is wholly federal) and the federal component of the SSI “minimum” rise by exactly the same percentage. 42 U.S.C. §§ 415(i), 1382f. The $20 income disregard, however, does not expand with inflation. Nor, unless the state so provides, does the state component of SSI. Cf. Reichenthal v. Harris, 492 F.Supp. 637, 640 (E.D.N.Y.1980); 42 U.S.C. §

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