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
- Whether a facially neutral reduction in Medicaid inpatient hospital days violates § 504 solely because it disproportionately affects individuals with disabilities.
- 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.