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

In Alexander v. Choate, 469 U.S. 287 (1985), the State of Tennessee reduced from 20 to 14 the number of inpatient hospital days it would reimburse for Medicaid beneficiaries. A class action was brought under Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. § 794), claiming the limitation would have a disproportionate effect on the handicapped and that it would disadvantage them disproportionately. The Supreme Court reversed the Sixth Circuit, finding that even if Section 504 supports some claims of disproportionate impact discrimination, it did not support a claim in this case; the reduction in inpatient days was not discriminatory on its face and nothing in Section 504’s legislative history suggests that Congress desired to make major inroads on the States’ longstanding discretion to choose the proper mix of amount, scope, and durational limitations on services covered by Medicaid. At footnote one, the Court restates: “Medicaid was established by Title XIX of the Social Security Act of 1965, 79 Stat. 343, as amended, 42 U. S. C. § 1396 et seq. Medicaid is a joint state-federal funding program for medical assistance in which the Federal Government approves a state plan for the funding of medical services for the needy and then subsidizes a significant portion of the financial obligations the State has agreed to assume. Once a State voluntarily chooses to participate in Medicaid, the State must comply with the requirements of Title XIX and applicable regulations. Harris v. McRae, 448 U.S. 297, 301 (1980).”

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