You'll hear argument first this morning in case 23-715 Advocate Christ Medical Center versus Bacera.

Ms. Sherry?

Mr. Chief Justice, and may it please the Court, the same words in the same sentence should

have the same meaning. Today, we are talking about the words entitled to benefits in the

dish adjustment.

Just two terms ago in Empire Health, this Court looked at the words entitled to benefits under Medicare Part A and said that it means qualifying for the Medicare Part A program.

Entitled to SSI benefits in the same sentence should mean the same thing, qualifying for the SSI program.

A person qualifies for the SSI program when she applies and is determined eligible,

and that eligibility lasts until it is terminated.

The government disagrees because it says that there's no such thing as an SSI program, and the only

SSI benefit is a monthly cash payment. But Congress created what it called a national program,

and it created a program of income insurance. This is a program where a person who's low

income enough to qualify in the first place is promised a minimum guaranteed income for a calendar year.

And in the months where that income is not needed, the cash payment is suspended, nothing is terminated, and other benefits remain available.

In the end, this is about DISH, and DISH is about ensuring that hospitals

are reimbursed for low-income patients that are less healthy and that are costlier to treat.

And health does not change overnight. The government's interpretation simply does not count

that low-income population. It does not count the low-income population.

It does not count the low-income Medicaid patient coming out of a nursing home.

It does not count the low-income patient waiting for her first check.

And the list of those it does not count goes on and on.

A dish proxy that does not measure the low-income population is no proxy at all.

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