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
CourtSupreme Court of the United States
DecidedFebruary 20, 2002
Docket00-952
StatusPublished
Cited by175 cases

This text of 534 U.S. 473 (Wisconsin Department of Health & Family Services v. Blumer) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
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).

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]*478spousal 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]*479I

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]*480Similarly, 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]*481the 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.

Other provisions specifically address income allocation in the period after the institutionalized spouse becomes Medicaid eligible. Section 1396r-5(b)(2)(A) prescribes, as a main rule, that if payment of income is made solely in the name of one spouse, that income is treated as available only to the named spouse (the “name-on-the-check” rule). Section 1396r-5(d) provides a number of exceptions to that main rule designed to ensure that the community spouse and other dependents have income sufficient to meet basic needs. Among the exceptions, § 1396r-5(d)(3) establishes for the community spouse a “minimum monthly maintenance needs allowance,” or MMMNA. The MMMNA is calculated by multiplying the federal poverty level for a couple by a percentage set by the State. Since 1992, that percentage must be at least 150%, §§ 1396r-5(d)(3)(A)-(B), but the resulting MMMNA may not exceed $1,500 per month in 1988 dollars ($2,175 in 2001 dollars), §§ 1396r-5(d)(3)(C), (g).2

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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, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wisconsin-department-of-health-family-services-v-blumer-scotus-2002.