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Becerra v. Gresham

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Supreme Court of the United States
Becerra v. Gresham
Docket number: 20-37
Term: 2020
Court: United States Supreme Court
Court membership
Chief Justice John G. Roberts • Clarence Thomas • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett
This article is about the court case previously known as Azar v. Gresham; it became Cochran v. Gresham when Norris Cochran became acting secretary of the U.S. Department of Health and Human Services (HHS) and Becerra v. Gresham when Xavier Becerra became secretary of HHS.

Becerra v. Gresham is a U.S. Supreme Court case that concerned a dispute about whether the U.S. Department of Health and Human Services has the authority to approve state-imposed work requirements for some Medicaid recipients. At issue is whether HHS approval of work requirements that aim to free up state Medicaid dollars by helping beneficiaries get healthcare coverage promotes the objectives of Medicaid.[1]

On March 11, the court removed the case from its March 2021 argument calendar following a request from Joe Biden's (D) acting solicitor general Elizabeth Prelogar.[2] The case had been scheduled for argument before the Supreme Court of the United States on March 29, 2021, during the court's October 2020-2021 term.

The case came on a writ of certiorari to the United States Court of Appeals for the District of Columbia Circuit. It was consolidated with Arkansas v. Gresham[3][4]

HIGHLIGHTS
  • The case: The U.S. Department of Health and Human Services (HHS) approved waivers from Medicaid requirements for states who asked to impose work requirements on certain beneficiaries. Citizens in some states who lost or faced the loss of benefits sued, arguing that HHS violated the U.S. Constitution and the Administrative Procedure Act (APA) when it approved the work requirements. The U.S. District Court for the District of Columbia and the U.S. Court of Appeals for the District of Columbia Circuit ruled against HHS. Those courts held that the agency did not properly consider the core objectives of Medicaid and failed the arbitrary-or-capricious test by approving the state work requirements. The Federal Government appealed to the U.S. Supreme Court, arguing that HHS has the authority to grant waivers in these cases.
  • The issue:
    "Whether the court of appeals erred in concluding that the Secretary may not authorize demonstration projects to test requirements that are designed to promote the provision of health-care coverage by means of facilitating the transition of Medicaid beneficiaries to commercial coverage and improving their health."
  • The outcome: The appeal is pending adjudication before the U.S. Supreme Court.


    • Click here to review the lower court's opinion.

    Why it matters: A decision to deny the authority of HHS to approve work requirements for state Medicaid beneficiaries would endorse a narrow reading of the Medicaid statute and only allow waivers for state programs designed to expand Medicaid enrollment. A decision to uphold the HHS decision to approve work requirements for some state Medicaid beneficiaries would endorse a broader reading of the requirements of the Medicaid statute. Such a reading would allow states to experiment with programs that aim to do more than expand the population of Medicaid beneficiaries.

    Timeline

    The following timeline details key events in this case:

    • March 18, 2021: Cochran v. Gresham became Becerra v. Gresham when Xavier Becerra became secretary of the U.S. Department of Health and Human Services.[5]
    • March 11, 2021: The U.S. Supreme Court removed the case from its March 2021 argument session.[2]
    • February 1, 2021: The U.S. Supreme Court set oral argument for March 29, 2021.
    • January 20, 2021: Azar v. Gresham became Cochran v. Gresham when Norris Cochran became acting secretary of the U.S. Department of Health and Human Services.[6]
    • December 4, 2020: The U.S. Supreme Court agreed to hear the case.
    • July 13, 2020: Acting U.S. Solicitor General Jeffrey B. Wall filed a petition for a writ of certiorari asking the U.S. Supreme Court to take the case.
    • February 14, 2020: The U.S. Court of Appeals for the District of Columbia Circuit affirmed the judgment of the district court.
    • March 27, 2019: The U.S. District Court for the District of Columbia vacated the approval of Arkansas Medicaid work requirements by Secretary of Health and Human Services Alex Azar.

    Background

    HHS approves Medicaid work requirement demonstration projects

    In 2018, the U.S. Department of Health and Human Services (HHS) began approving demonstration projects to test the effects of work and skill-building requirements on Medicaid recipients. In Arkansas, HHS approved the state's request for a waiver from Medicaid's traditional requirements for three years. Arkansas asked to test the effects of requiring Medicaid beneficiaries who were able-bodied, not caring for children, not going to school, and not pregnant " to spend at least 80 hours per month performing activities that include working, looking for work, job-skills training, education, and community service." Arkansas argued that the program aimed to help beneficiaries better themselves economically and either obtain employer-sponsored health insurance or individual coverage through the public ACA exchange.[1]

    In New Hampshire, HHS approved for five years a similar program to the one in Arkansas that required beneficiaries to spend 100 hours a month in work or skill-building activities.[1]

    District court blocks Arkansas Medicaid work requirements

    In March 2019, the United States District Court for the District of Columbia vacated HHS's approval of the Arkansas waiver request. The court held that HHS had not properly considered whether the work requirements would help Arkansas provide medical coverage, which the court said was the main objective of the Medicaid program. The court sent the Arkansas waiver request back to HHS for further consideration.[1][7]

    District court blocks similar New Hampshire program

    In April 2019, the same district court that blocked the Arkansas program ruled against HHS's approval of New Hampshire's program. The court ruled that HHS has failed to consider the core Medicaid objective of providing health-care coverage to the needy. The court held that state efforts to transition people to other coverage were not sufficient.[1]

    Appeal to the D.C. Circuit

    The federal government and the states appealed the decisions of the district court to the United States Court of Appeals for the District of Columbia Circuit. The D.C. Circuit affirmed the ruling of the district court. It held that "the principal objective of Medicaid is providing health care coverage" and that HHS had focused on alternative goals that go beyond what the agency may consider when deciding whether to grant a waiver from Medicaid requirements. The D.C. Circuit concluded that HHS approval of the state work requirements failed the arbitrary-or-capricious test, which comes from the Administrative Procedure Act (APA) and instructs federal courts to invalidate actions that are arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with the law.[1]

    Appeal to the U.S. Supreme Court

    The federal government appealed and the U.S. Supreme Court agreed to hear the case on December 4, 2020.[8]

    Biden administration changes policy and asks U.S. Supreme Court to vacate lower court decisions

    The Joe Biden (D) administration started taking steps to reverse the HHS waivers granted during the Donald Trump (R) administration.[2] Next, the Biden administration asked the U.S. Supreme Court to cancel oral argument and vacate the lower court decisions, which would allow HHS to reconsider the waivers at issue in the case without limiting the agency's authority.[2] On March 11, 2021, the court agreed to cancel the scheduled March 29 oral argument but it did not vacate the lower court's decisions at that time.[2]

    Question presented

    The U.S. Supreme Court granted the petitions for writs of certiorari and consolidated the cases to consider the following question:[1]

    Questions presented:
    “ Whether the court of appeals erred in concluding that the Secretary may not authorize demonstration projects to test requirements that are designed to promote the provision of health-care coverage by means of facilitating the transition of Medicaid beneficiaries to commercial coverage and improving their health.[9] ”

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 Supreme Court of the United States, "Azar v. Gresham: "Petition for a writ of certiorari," July 2020
    2. ↑ 2.0 2.1 2.2 2.3 2.4 SCOTUSblog, "Court nixes upcoming argument on Medicaid work requirements," March 11, 2021
    3. ↑ Arkansas v. Gresham also came on a writ of certiorari to the U.S. Court of Appeals for the District of Columbia Circuit. The docket number is 20-38.
    4. ↑ When the U.S. Supreme Court agreed to hear the case, Becerra v. Gresham was called Azar v. Gresham. Alex Azar was secretary of HHS during the Donald Trump (R) administration. The case changed names when Norris Cochran became acting secretary of HHS on January 20, 2021, following the inauguration of President Joe Biden (D). The case changed names again when Xavier Becerra became secretary of HHS.
    5. ↑ Los Angeles Times, "California’s Xavier Becerra confirmed as Health and Human Services secretary," March 18, 2021
    6. ↑ Bloomberg Law, "Norris Cochran Named Acting HHS Head as Becerra Awaits Hearing," January 20, 2021
    7. ↑ United States District Court for the District of Columbia, Gresham v. Azar, March 27, 2019
    8. ↑ U.S. Supreme Court, "Order List," December 4, 2020
    9. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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