Wisconsin Department of Health & Family Services v. Blumer

534 U.S. 473, 122 S. Ct. 962, 151 L. Ed. 2d 935, 15 Fla. L. Weekly Fed. S 109, 186 A.L.R. Fed. 639, 2002 Cal. Daily Op. Serv. 1583, 2002 Daily Journal DAR 1909, 2002 U.S. LEXIS 1173, 70 U.S.L.W. 4139
Supreme Court of the United States·Decided February 20, 2002·No. 00-952·Published·Cited by 175 cases

Opinions

Justice Ginsburg

delivered the opinion of the Court.

This case requires interpretation of the “spousal impoverishment” provisions of the Medicare Catastrophic Coverage Act of 1988 (MCCA or Act), 102 Stat. 754, 42 U. S. C. § 1396r-5 (1994 ed. and Supp. V), a complex set of instructions made part of the federal Medicaid statute. The [478] spousal impoverishment provisions permit a spouse living at home (called the “community spouse”) to reserve certain income and assets to meet the minimum monthly maintenance needs he or she will have when the other spouse (the “institutionalized spouse”) is institutionalized, usually in a nursing home, and becomes eligible for Medicaid.

The Act shelters from diminution a standard amount of assets (called the “community spouse resource allowance,” “CSRA,” or “resource allowance”). The MCCA allows an increase in the standard allowance if either spouse shows, at a state-administered hearing, that the community spouse will not be able to maintain the statutorily defined minimum level of income on which to live after the institutionalized spouse gains Medicaid eligibility.

In determining whether the community spouse is entitled to a higher CSRA, i. e., to shelter assets in excess of the standard resource allowance, Wisconsin, like a majority of other States, uses an “income-first” method. Under that method, the State considers first whether potential income transfers from the institutionalized spouse, which the MCCA expressly permits, will suffice to enable the community spouse to meet monthly needs once the institutionalized spouse qualifies for Medicaid.

Respondent Irene Blumer, whose Medicaid eligibility was delayed by the application of petitioner Wisconsin Department of Health and Family Services’ income-first method, challenges that method as inconsistent with the MCCA provision governing upward revision of the community spouse resource allowance, § 1396r-5(e)(2)(C) (1994 ed.). The Wisconsin Court of Appeals upheld her challenge. We reverse that court’s judgment. Neither the text of § 1396r-5(e)(2)(C) nor the structure of the MCCA, we conclude, forbids Wisconsin’s chosen approach. Consistent with the position adopted by the Secretary of Health and Human Services, we hold that the income-first method represents a permissible interpretation of the Act.

[479] I

A

The federal Medicaid program provides funding to States that reimburse needy persons for the cost of medical care. See Social Security Act, tit. XIX, as added, 79 Stat. 343, and as amended, 42 U. S. C. § 1396 et seq. (1994 ed. and Supp. V). “Each participating State develops a plan containing reasonable standards ... for determining eligibility for and the extent of medical assistance” within boundaries set by the Medicaid statute and the Secretary of Health and Human Services. Schweiker v. Gray Panthers, 453 U. S. 34, 36-37 (1981) (internal quotation marks omitted); § 1396a(a)(17) (1994 ed.).1 In formulating those standards, States must “provide for taking into account only such income and resources as are, as determined in accordance with standards prescribed by the Secretary, available to the applicant.” § 1396a(a)(17)(B) (emphasis added).

Because spouses typically possess assets and income jointly and bear financial responsibility for each other, Medicaid eligibility determinations for married applicants have resisted simple solutions. See, e.g., id., at 44-48. Until 1989, the year the MCCA took effect, States generally considered the income of either spouse to be “available” to the other. We upheld this approach in Gray Panthers, observing that “from the beginning of the Medicaid program, Congress authorized States to presume spousal support.” Id., at 44; see id., at 45 (quoting passage from S. Rep. No. 404, 89th Cong., 1st Sess., pt. 1, p. 78 (1965), including statement that “it is proper to expect spouses to support each other”). [480] Similarly, assets held jointly by the couple were commonly deemed “available” in full to the institutionalized spouse.

At the same time, States generally did not treat resources held individually by the community spouse as available to the institutionalized spouse. Accordingly, assets titled solely in the name of the community spouse often escaped consideration in determining the institutionalized spouse’s Medicaid eligibility. See H. R. Rep. No. 100-105, pt. 2, pp. 66-67 (1987).

As Congress later found when it enacted the MCCA in 1988, these existing practices for determining, a married applicant’s income and resources produced unintended consequences. Many community spouses were left destitute by the drain on the couple’s assets necessary to qualify the institutionalized spouse for Medicaid and by the diminution of the couple’s income posteligibility to reduce the amount payable by Medicaid for institutional care. See id., at 66-68. Conversely, couples with ample means could qualify for assistance when their assets were held solely in the community spouse’s name.

In the MCCA, Congress sought to protect community spouses from “pauperization” while preventing financially secure couples from obtaining Medicaid assistance. See id., at 65 (bill seeks to “end th[e] pauperization” of the community spouse “by assuring that the community spouse has a sufficient — but not excessive — amount of income and resources available”). To achieve this aim, Congress installed a set of intricate and interlocking requirements with which States must comply in allocating a couple’s income and resources.

Income allocation is governed by §§1396r-5(b) and (d). Covering any month in which “an institutionalized spouse is in the institution,” § 1396r-5(b)(l) provides that “no income of the community spouse shall be deemed available to the institutionalized spouse.” The community spouse’s income is thus preserved for that spouse and does not affect [481] the determination whether the institutionalized spouse qualifies for Medicaid. In general, such income is also disregarded in calculating the amount Medicaid will pay for the institutionalized spouse’s care after eligibility is established.

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Wisconsin Department of Health & Family Services v. Blumer, 534 U.S. 473, 122 S. Ct. 962, 151 L. Ed. 2d 935, 15 Fla. L. Weekly Fed. S 109, 186 A.L.R. Fed. 639, 2002 Cal. Daily Op. Serv. 1583, 2002 Daily Journal DAR 1909, 2002 U.S. LEXIS 1173, 70 U.S.L.W. 4139 (2002).

534 U.S. 473 (Wisconsin Department of Health & Family Services v. Blumer) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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