## Facts

- Tennessee administered a federally funded Medicaid program that covered inpatient hospital services.
- To address rising costs, Tennessee reduced the number of inpatient hospital days Medicaid would pay for per recipient per year from 20 to 14.
- A class of Medicaid recipients, including individuals with disabilities, sued before the change took effect.
- Plaintiffs alleged the 14-day cap would disproportionately harm disabled recipients because they were more likely to need longer hospital stays.
- Plaintiffs claimed the reduction constituted discrimination under § 504 of the Rehabilitation Act of 1973, which bars discrimination against an otherwise qualified person with a disability in programs receiving federal financial assistance.

## Issues

1. Whether a facially neutral reduction in Medicaid inpatient hospital days violates § 504 solely because it disproportionately affects individuals with disabilities.
2. Whether § 504 (and its implementing regulations) reach disparate-impact claims, and if so, whether Tennessee’s 14-day cap is prohibited disparate impact.

## Decision

- The Supreme Court reversed the Sixth Circuit and upheld Tennessee’s 14-day annual inpatient hospital limit.
- The Court assumed, without deciding, that § 504 and its regulations can reach some disparate-impact discrimination.
- Even on that assumption, the Court held the 14-day cap did not violate § 504 because it did not deny disabled recipients meaningful access to the Medicaid benefit Tennessee chose to provide.
- The Court emphasized the cap was facially neutral, was not alleged to be motivated by discriminatory intent, and applied equally to all recipients.
- The Court rejected the view that § 504 required Tennessee to provide more coverage to disabled recipients to account for greater medical need.

## Legal Principles

- Section 504 is an antidiscrimination provision aimed at evenhanded treatment and opportunity to participate in and benefit from covered programs; it does not guarantee equal results.
- A central inquiry under § 504 is whether disabled individuals have “meaningful access” to the benefit offered by the program.
- A public program may define the scope of the benefit it provides; § 504 generally does not require altering the benefit’s definition solely because disabled individuals may need more of it.
- Disparate impact alone does not establish a § 504 violation where the challenged limit provides the same, equally available benefit to disabled and nondisabled participants and does not exclude disabled persons from participation.

## Conclusion

The Court held that Tennessee’s across-the-board reduction of Medicaid inpatient hospital coverage to 14 days per year did not violate § 504 because disabled recipients retained meaningful access to the same package of benefits offered to all recipients, and § 504 did not require the state to increase coverage to equalize health outcomes.


Alexander v. Choate, 469 U.S. 287 (1985)