Thank You For Submiting Feedback!
Supreme Court of the United States
January 10, 2022, Argued; June 6, 2022, Decided
Justice Thomas delivered the opinion of the Court.
] Medicaid requires participating States to pay for certain needy individuals’ medical costs and then to make reasonable efforts to recoup those costs from liable third parties. Consequently, a State must require Medicaid beneficiaries to assign the State “any rights . . . to payment for medical care from any third party.” 42 U. S. C. §1396k(a)(1)(A). That assignment permits a State to seek reimbursement from the portion of a beneficiary’s private tort settlement that represents [*8] “payment for medical care,” ibid., despite the Medicaid Act’s general prohibition against seeking reimbursement from a beneficiary’s “property,” §1396p(a)(1). The question presented is whether §1396k(a)(1)(A) permits a State to seek reimbursement from settlement payments allocated for future medical care. We conclude that it does.
] States participating in Medicaid “must comply with [the Medicaid Act’s] requirements” or risk losing Medicaid funding. Harris v. McRae, 448 U. S. 297, 301, 100 S. Ct. 2671, 65 L. Ed. 2d 784 (1980); see 42 U. S. C. §1396c. Most relevant here, the Medicaid Act requires a State to condition Medicaid eligibility on a beneficiary’s assignment to the State of “any rights . . . to support . . . for the purpose of medical care” and to “payment for medical care from any third party.” §1396k(a)(1)(A); see also §1396a(a)(45) (mandating States’ compliance with §1396k). The State must also enact laws by which it automatically acquires a right to certain third-party payments “for health care items or services furnished” to a beneficiary. §1396a(a)(25)(H). And the State must use these (and other) tools to “seek reimbursement” from third parties “to the extent of [their] legal liability” for a beneficiary’s “care and services available under the plan.” §§1396a(a)(25)(A)-(B).
] The Medicaid Act also sets a limit on States’ efforts to recover their expenses. The Act’s [*9] “anti-lien provision” prohibits States from recovering medical payments from a beneficiary’s “property.” §1396p(a)(1); see also §1396a(a)(18) (requiring state Medicaid plans to comply with §1396p). Because a “beneficiary has a property right in the proceeds of [any] settlement,” the anti-lien provision protects settlements from States’ reimbursement efforts absent some statutory exception. Wos v. E. M. A., 568 U. S. 627, 633, 133 S. Ct. 1391, 185 L. Ed. 2d 471 (2013). State laws “requir[ing] an assignment of the right . . . to receive payments [from third parties] for medical care,” as “expressly authorized by the terms of §§1396a(a)(25) and 1396k(a),” are one such exception. Arkansas Dept. of Health and Human Servs. v. Ahlborn, 547 U. S. 268, 284, 126 S. Ct. 1752, 164 L. Ed. 2d 459 (2006). Accordingly, a State may seek reimbursement from the portion of a settlement designated for the “medical care” described in those provisions; otherwise, the anti-lien provision prohibits reimbursement. Id., at 285, 126 S. Ct. 1752, 164 L. Ed. 2d 459.
Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.
2022 U.S. LEXIS 2683 *; __ S.Ct. __; 2022 WL 1914096
GIANINNA GALLARDO, AN INCAPACITATED PERSON, BY AND THROUGH HER PARENTS AND CO-GUARDIANS PILAR VASSALLO AND WALTER GALLARDO, PETITIONER v. SIMONE MARSTILLER, IN HER OFFICIAL CAPACITY AS SECRETARY OF THE FLORIDA AGENCY FOR HEALTH CARE ADMINISTRATION
Notice: The Lexis pagination of this document is subject to change pending release of the final published version.
Prior History: [*1] ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT
Gallardo v. Dudek, 963 F.3d 1167, 2020 U.S. App. LEXIS 19928, 2020 WL 3478027 (11th Cir. Fla., June 26, 2020)
Disposition: 963 F. 3d 1167, affirmed.
medical care, settlement, provisions, third-party, assignment provision, anti-lien, expenses, rights, medical expenses, third party, state plan, reimbursement, insurers, medical assistance, seek reimbursement, provisions of a liability, allocated, acquisition, Medicaid Act, damages, funds, anti-recovery, future medical expenses, compensate, healthcare, assign, unfair, costs, statutory context, legal liability
Public Health & Welfare Law, Medicaid, State Plans, Third Party Claims, Approvals, Social Security, Medicaid Act Interpretation, Compliance, Eligibility, Categorically & Medically Needy Claimants, Amount, Duration & Scope of Benefits, Torts, Damages, Collateral Source Rule, Government Benefits, Healthcare, Services for Disabled & Elderly Persons, Costs, Evidence, Burdens of Proof, Clear & Convincing Proof, Compensatory Damages, Types of Losses, Medical Expenses, Governments, Legislation, Interpretation, Civil Procedure, Parties, Real Party in Interest, Assignees