`(Slip Opinion)
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`
` OCTOBER TERM, 2021
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`Syllabus
`
`1
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` NOTE: Where it is feasible, a syllabus (headnote) will be released, as is
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`
`
` being done in connection with this case, at the time the opinion is issued.
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` The syllabus constitutes no part of the opinion of the Court but has been
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` prepared by the Reporter of Decisions for the convenience of the reader.
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` See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.
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`
`SUPREME COURT OF THE UNITED STATES
`
`
`
` Syllabus
`
`BECERRA, SECRETARY OF HEALTH AND HUMAN
`SERVICES v. EMPIRE HEALTH FOUNDATION, FOR
`
`VALLEY HOSPITAL MEDICAL CENTER
`
`CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR
`
`THE NINTH CIRCUIT
` No. 20–1312. Argued November 29, 2021—Decided June 24, 2022
`
`
` Once a person turns 65 or has received federal disability benefits for 24
` months, he becomes “entitled” to benefits under Part A of Medicare.
`
`
`
`
` 42 U. S. C. §§426(a)–(b). Part A provides coverage for, among other
` things, inpatient hospital treatment. See §1395d(a). Medicare pays
`
`hospitals a fixed rate for such treatment based on the patient’s diag-
`nosis, regardless of the hospital’s actual cost and subject to certain ad-
`
` justments. §§1395ww(d)(1)–(5). One such adjustment is the “dispro-
`portionate share hospital” (DSH) adjustment, which provides higher-
`
` than-usual rates to hospitals that serve a higher-than-usual percent-
`age of low-income patients. To calculate the DSH adjustment, the De-
`partment of Health and Human Services (HHS) adds together two
`statutorily described fractions: the Medicare fraction—which repre-
` sents the proportion of a hospital’s Medicare patients who have low
`
`incomes—and the Medicaid fraction—which represents the proportion
`
`
` of a hospital’s total patients who are not entitled to Medicare and have
`low incomes. Together those fractions produce the “disproportionate-
`patient percentage,” which determines whether a hospital will receive
`a DSH adjustment, and how large it will be.
`
`Not all patients who qualify for Medicare Part A have their hospital
`treatment paid for by the program. Non-payment may occur, for ex-
`ample, if a patient’s stay exceeds Medicare’s 90-day cap per spell of
`illness, see §1395d, or if a patient is covered by a private insurance
`
`plan, see §1395y(b)(2)(A). Such limits on Medicare’s coverage prompt
`
`
`the question raised here: whether patients whom Medicare insures but
`does not pay for on a given day are patients “who (for such days) were
`
`
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`

`

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`
`2
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`
`BECERRA v. EMPIRE HEALTH FOUNDATION, FOR
`
`VALLEY HOSPITAL MEDICAL CENTER
`
`Syllabus
`entitled to [Medicare Part A] benefits” for purposes of computing a hos-
`
`pital’s disproportionate-patient percentage. §1395ww(d)(5)(F)(vi)(I).
`
`
`A 2004 HHS regulation says yes: If the patient meets the basic stat-
`
`utory criteria for Medicare (i.e., is over 65 or disabled), then the patient
`
`counts in the denominator and, if poor, in the numerator of the Medi-
`
`care fraction. See 69 Fed. Reg. 49098–49099. Respondent Empire
`Health Foundation challenged that regulation as inconsistent with the
`
`
`
`statute. The Ninth Circuit agreed. That court focused on the statute’s
`
`use of two different phrases: “entitled to [Medicare Part A] benefits”
`and “eligible for [Medicaid] assistance.” The Ninth Circuit read the
`
`latter phrase to mean that a patient qualifies for Medicaid and the
`former phrase to mean that a patient has an absolute right to payment
`from Medicare. The Court granted certiorari to resolve a conflict be-
`tween the Ninth Circuit and two other Circuit Courts, which had ap-
`
`proved of HHS’s regulation.
`
`Held: In calculating the Medicare fraction, individuals “entitled to [Med-
`icare Part A] benefits” are all those qualifying for the program, regard-
`
`less of whether they receive Medicare payments for part or all of a hos-
`
`pital stay. Pp. 7–19.
`
`HHS’s regulation is consistent with the text, context, and structure
`of the DSH provisions. The agency has interpreted the phrase “enti-
`
`tled to benefits” in those provisions to mean just what it means
`throughout the Medicare statute: qualifying for benefits. And count-
`ing everyone who qualifies for Medicare benefits in the Medicare frac-
`tion—and no one who qualifies for those benefits in the Medicaid frac-
`tion—accords with the statute’s attempt to capture, through two
`separate measurements, two different segments of a hospital’s low-in-
`come patient population.
`
`(a) Empire’s textual argument has a two-part structure. Echoing
`
`the Ninth Circuit, Empire primarily contends that the words “entitled”
`and “eligible” have different meanings. According to Empire, to be “el-
`
`igible” for a benefit is to be “qualified” to seek it; to be “entitled” to a
`benefit means instead to have an “absolute right” to its payment. But
`
`throughout the Medicare statute, “entitled to benefits” is essentially a
`term of art meaning “qualifying for benefits,” i.e., being over 65 or dis-
`
`
`
`abled. And in the end, Empire basically concedes that point. It must
`
`devise a way to give “entitled to benefits” a different meaning in the
`
`fraction descriptions than everywhere else in the Medicare statute. So
`
`Empire shifts gears, relying now on the parenthetical phrase “(for such
`days)” to transform the usual statutory meaning of “entitled to bene-
`
`fits” to something different and novel. But those three little words do
`not accomplish what Empire would like, having the much less radical
`function of excluding days of a patient’s hospital stay before he quali-
`
`fies for Medicare (e.g., turns 65). Pp. 8–15.
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`
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`

`

`3
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`
`Cite as: 597 U. S. ____ (2022)
`
`
`Syllabus
`
`
`
`(1) The Medicare statute explicitly states that “[e]very individual”
`
`who “has attained age 65” and is entitled to ordinary social security
`payments and “every individual” under age 65 who has been entitled
`
`to federal disability benefits for at least 24 months “shall be entitled
`
`to” Medicare Part A benefits. §§426(a)–(b). This broad meaning of
`“entitlement” coexists with limitations on payment. The entitlement
`to benefits, the statute repeatedly says, is an entitlement to payment
`
`under specified conditions. So a person remains entitled to benefits
`
`even if he has run into one of the statute’s conditions, such as the 90-
`
`day cap on inpatient hospital services. For example, the statute twice
`
`refers to patients who are “entitled to benefits under part A but ha[ve]
`
`exhausted benefits for inpatient hospital services.” §§1395l(a)(8)(B)(i),
`1395l(t)(1)(B)(ii). In thus describing the Part A entitlement, the stat-
`
`ute reflects the complexity of health insurance: An insured who hits
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`some limit on coverage for, say, eye care is still insured. His policy will
`
`pay for more eye care in the next coverage period and meanwhile will
`
`pay for his knee replacement.
`
`
`If “entitled to benefits” instead bore Empire’s meaning, Medicare
`beneficiaries would lose important rights and protections, such as the
`ability to enroll in other Medicare programs. See §§1395o(a), 1395w-
`
`
`21(a)(3), 1395w–101(a)(3)(A). Empire’s interpretation would also
`make a hash of provisions designed to inform Medicare beneficiaries
`
`of their benefits, see §1395b–2(a), and to protect beneficiaries from
`misleading marketing materials, see §1395w–21(a)(3). Congress could
`not have intended to write a statute whose safeguards would apply or
`not apply, or fluctuate constantly, based on the happenstance of
`
`
`
`whether Medicare paid for hospital care on a given day. Pp. 9–13.
`
`
`(2) Empire concedes that its interpretation cannot be applied
`
`throughout the Medicare statute. To get around this, Empire claims
`that the parenthetical in “patients who (for such days) were entitled to
`[Part A] benefits,” §1395ww(d)(5)(F)(vi)(I), converts the usual statu-
`
`
`tory meaning of “entitled to benefits” to something different: actually
`
`receiving payment. That slight phrase, however, cannot bear so much
`interpretive weight. Instead, the parenthetical works as HHS says:
`hand in hand with the ordinary statutory meaning of “entitled to ben-
`efits.” It directs HHS to count only those individuals who qualify for
`
`
`Medicare on a particular day. So if a patient turns 65 on the 15th day
`of a 30-day hospital stay, HHS will count only 15 days. Pp. 13–15.
`
`(b) The structure of the relevant statutory provisions reinforces the
`
`conclusion that “entitled to benefits” means qualifying for benefits.
`The statute recompenses hospitals for serving two different low-in-
`come populations: low-income Medicare patients and low-income non-
`
`
`Medicare patients. HHS’s reading of “entitled” comports with this
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`

`

`4
`
`
`BECERRA v. EMPIRE HEALTH FOUNDATION, FOR
`
`VALLEY HOSPITAL MEDICAL CENTER
`
`Syllabus
`
`structure: a low-income Medicare patient always count in the Medi-
`
`
`care fraction. That is so regardless of whether the Medicare program
`
`is actually paying for a day of his care—because that fact has no rela-
`
`tionship to his financial status. Empire’s interpretation, by contrast,
`
`fits poorly with the statutory structure. Its who-paid-for-a-day-of-care
`
`test has no relationship to a patient’s financial status. So on Empire’s
`view, a patient could phase in and out of the Medicare fraction regard-
`less of income. Empire responds by asserting that any low-income per-
`son excluded from the Medicare fraction (say, because of exhaustion of
`benefits) would get counted instead in the Medicaid fraction. But even
`if that is true, Empire’s scheme would result in patients ping-ponging
`back and forth between the two fractions based on the happenstance
`
`of actual Medicare payments. In any event, Empire is too quick to
`claim that those who (on its view) are tossed from the Medicare frac-
`tion for non-income-based reasons like exhaustion of benefits would
`still wind up in the Medicaid fraction. Applying Empire’s reading of
`
`“for such days,” a low-income patient who has exhausted his coverage
`
`
`
`would not get counted at all, in either fraction, but he would remain
`just as low-income and impose just as high costs on the hospital treat-
`ing him. Empire’s only response is to insist that its interpretation
`
`must be right because it usually (though not always) leads to higher
`
`DSH payments. But the point of the statute is not to pay hospitals the
`most money possible; it is to compensate them for serving a dispropor-
`
`tionate share of low-income patients. Pp. 15–18.
`958 F. 3d 873, reversed and remanded.
`KAGAN, J., delivered the opinion of the Court, in which THOMAS,
`BREYER, SOTOMAYOR, and BARRETT, JJ., joined. KAVANAUGH, J., filed a
`dissenting opinion, in which ROBERTS, C. J., and ALITO and GORSUCH,
`JJ., joined.
`
`
`
`

`

`
`
`
`
` Cite as: 597 U. S. ____ (2022)
`
`Opinion of the Court
`
`1
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` NOTICE: This opinion is subject to formal revision before publication in the
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`
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` preliminary print of the United States Reports. Readers are requested to
`
`
` notify the Reporter of Decisions, Supreme Court of the United States, Wash-
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` ington, D. C. 20543, of any typographical or other formal errors, in order that
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`
` corrections may be made before the preliminary print goes to press.
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`
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`SUPREME COURT OF THE UNITED STATES
`
`_________________
`
` No. 20–1312
`_________________
` XAVIER BECERRA, SECRETARY OF HEALTH AND
`
`
` HUMAN SERVICES, PETITIONER v. EMPIRE
`HEALTH FOUNDATION, FOR VALLEY
`
` HOSPITAL MEDICAL CENTER
`ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF
`
`APPEALS FOR THE NINTH CIRCUIT
`[June 24, 2022]
`JUSTICE KAGAN delivered the opinion of the Court.
`The Medicare program reimburses hospitals at higher-
`
`than-usual rates when they serve a higher-than-usual per-
`centage of low-income patients. The enhanced rates are cal-
`culated by adding together two fractions, called the Medi-
`care fraction and the Medicaid fraction. Roughly speaking,
`
`the former measures the hospital’s low-income senior-citi-
`zen population, and the latter the hospital’s low-income
`
`non-senior population.
`This case raises a technical but important question about
`
`the Medicare fraction. The statutory description of that
`
`fraction refers to “the number of [a] hospital’s patient days”
`
`attributable to low-income patients “who (for such days)
`
`were entitled to benefits under part A of [Medicare].” 42
`
`U. S. C. §1395ww(d)(5)(F)(vi)(I). According to the Depart-
`ment of Health and Human Services (HHS), a person is “en-
`titled to [Part A] benefits” under the statute if he qualifies
`for the Medicare program—essentially, if he is over 65 or
`
`
`
`
`

`

`2
`
`
`BECERRA v. EMPIRE HEALTH FOUNDATION, FOR
`VALLEY HOSPITAL MEDICAL CENTER
`
`Opinion of the Court
`disabled. That remains so even when Medicare is not pay-
`ing for part or all of his hospital stay—for example, because
`
`a private insurer is legally responsible or because he has
`used up his allotted coverage. Today, we approve HHS’s
`understanding of the Medicare fraction.
`I
`
`The Medicare program provides Government-funded
`health insurance to over 64 million elderly or disabled
`Americans. (The vast majority of that number are senior
`
`citizens.) When a person turns 65 or has received federal
`disability benefits for 24 months, he automatically (i.e.,
`
`
`without application or other filing) becomes “entitled” to
`benefits under Medicare Part A. §§426(a)–(b). The most
`significant Part A benefit is coverage for inpatient hospital
`treatment; Part A also covers associated physician and
`skilled nursing services. See §1395d(a); HHS, CMS
`
`Ruling No. CMS–1498–R, p. 10 (Apr. 28, 2010), https://
`www.cms.gov/regulations-and-guidance/guidance/rulings
`
`/downloads/cms1498r.pdf (CMS–1498–R). In addition, en-
`
`titlement to Part A generally enables a patient to enroll (if
`
`
`he wishes) in Medicare’s other programs: Part B’s coverage
`for outpatient care; Part C’s coverage through privately ad-
`ministered Medicare Advantage plans; and Part D’s cover-
`age for prescription drugs. See §§1395o(a)(1), 1395w–
`21(a)(3), 1395w–101(a)(3)(A).
`
`
`The Medicare program pays a hospital a fixed rate for
`treating each Medicare patient, based on the patient’s diag-
`
`nosis and regardless of the hospital’s actual costs.
`§§1395ww(d)(1)–(4). The rates are designed to reflect the
`amounts an efficiently run hospital, in the same region,
`
`would expend to treat a patient with the same diagnosis.
`
`See 42 CFR §412.2 (2022). If the hospital spends anything
`more, it suffers a financial loss. The flat-rate payment sys-
`tem thus gives hospitals an incentive to provide efficient
`levels of medical service.
`
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`
`
`
`

`

`
`
`3
`
`
`
` Cite as: 597 U. S. ____ (2022)
`
`Opinion of the Court
`But Congress, recognizing complexity in healthcare, pro-
`
`vided for various hospital-specific rate adjustments—in-
`cluding the one at issue here for treating low-income pa-
`tients.
`The “disproportionate share hospital” (DSH)
`adjustment gives hospitals serving an “unusually high per-
`centage of low-income patients” enhanced Medicare pay-
`
`ments. Sebelius v. Auburn Regional Medical Center, 568
`U. S. 145, 150 (2013). The mark-up reflects that low-in-
`
`come individuals are often more expensive to treat than
`higher income ones, even for the same medical conditions.
`In compensating for that disparity, the DSH adjustment en-
`courages hospitals to treat low-income patients.
`
`To calculate a hospital’s DSH adjustment, HHS adds to-
`
`gether two statutorily described fractions, usually called
`the Medicare fraction and the Medicaid fraction. Those
`
`fractions are designed to capture two different low-income
`
`populations that a hospital serves. The Medicare fraction
`
`represents the proportion of a hospital’s Medicare patients
`who have low incomes, as identified by their entitlement to
`
`supplementary security income (SSI) benefits. SSI is a
`“welfare program” providing benefits to “financially needy
`
`individuals” who (like Medicare patients generally) are over
`
`65 or disabled. Bowen v. Galbreath, 485 U. S. 74, 75 (1988);
`see §§1382(a)(1), 1382c(a)(1). The Medicaid fraction repre-
`sents the proportion of a hospital’s patients who are not en-
`titled to Medicare and have low incomes, as identified by
`their eligibility for Medicaid. The Medicaid program pro-
`vides health insurance to all low-income individuals, re-
`gardless of age or disability. See §1396d(a). So at a high
`
`
`level of generality, the Medicare fraction is a measure of a
`hospital’s senior (or disabled) low-income population, while
`the Medicaid fraction is a measure of a hospital’s non-senior
`(except for disabled) low-income population.
`
`
`With that under your belt, you might be ready to absorb
`
`the relevant statutory language (but don’t bet on it). The
`Medicare fraction is described as:
`
`
`
`
`
`

`

`
`
`4
`
`
`BECERRA v. EMPIRE HEALTH FOUNDATION, FOR
`VALLEY HOSPITAL MEDICAL CENTER
`
`Opinion of the Court
`“[a] fraction (expressed as a percentage), the numera-
`tor of which is the number of [a] hospital’s patient days
`
`for [the fiscal year] which were made up of patients who
`(for such days) were entitled to benefits under part A of
`
`[Medicare] and were entitled to [SSI] benefits[], and
`the denominator of which is the number of such hospi-
`tal’s patient days for such fiscal year which were made
`up of patients who (for such days) were entitled to ben-
`efits under [Medicare] part A.”
`§1395ww(d)(5)(F)
`(vi)(I).
`
`That is a mouthful (and without the brackets, it’s even
`
`worse). So again, in general terms: The numerator is the
`number of patient days attributable to Medicare patients
`who are poor. The denominator is the number of patient
`days attributable to all Medicare patients. Divide the for-
`mer by the latter to get the fraction “expressed as a percent-
`age.” Ibid.
`
`
`And similarly for the Medicaid fraction. That fraction is
`described as:
`“[a] fraction (expressed as a percentage), the numera-
`
`tor of which is the number of [a] hospital’s patient days
`for [the fiscal year] which consist of patients who (for
`
`such days) were eligible for medical assistance under
`[Medicaid], but who were not entitled to benefits under
`
`part A of [Medicare], and the denominator of which is
`
`the total number of the hospital’s patient days for such
`
`[fiscal year].” §1395ww(d)(5)(F)(vi)(II).
`That too is a lot to digest. So again, in general terms: The
`numerator is the number of patient days attributable to
`
`non-Medicare patients who are poor. The denominator is
`the total number of patient days. Divide the former by the
`latter to get the second percentage the DSH calculation re-
`
`quires.1
`——————
`1You may have noticed that the denominator of the Medicare fraction
`
`
`
`
`
`

`

`
`
`5
`
`
`Cite as: 597 U. S. ____ (2022)
`
`Opinion of the Court
`Once both percentages have been calculated, they are
`
`
`
` added together to produce the “disproportionate-patient
`percentage.” That percentage determines whether a hospi-
`tal will receive a DSH adjustment, and if so, how large it
`will be. The combined percentage must usually equal or
`exceed 15% for a hospital to get an adjustment. See
`§1395ww(d)(5)(F)(v). So, for example, if a hospital’s Medi-
`care fraction is 10% and its Medicaid fraction is 5%, then
`
`the hospital would qualify for increased rates. The higher
`the disproportionate-patient percentage goes, the greater
`the rate mark-up
`that
`the hospital will receive.
`§§1395ww(d)(5)(F)(vii)–(xiv).
`
`This case is about how to count patients who qualify for
`
`Medicare Part A—because they are over 65 or disabled—at
`times when the program is not paying for their hospital
`
`treatment. Such non-payment may occur for a number of
`reasons. For one, Medicare usually pays for only the first
`
`90 days of a hospital stay associated with a single “spell of
`
`illness.” See §1395d; 42 CFR §409.61(a). If a patient’s stay
`
`
`for an illness exceeds that limit, his coverage is “ex-
`hausted.” §409.61(a). For another, Medicare pays for hos-
`pital treatment only once a patient has used up other med-
`ical insurance. See §1395y(b)(2)(A). So if a patient has a
`
`private insurance plan, or is injured by a tortfeasor with
`insurance, Medicare will not pay unless and until that other
`——————
` (the number of patient days attributable to Medicare patients) is smaller
`
`than the denominator of the Medicaid fraction (the total number of pa-
` tient days). That means each low-income patient day included in the
`
`Medicare fraction will count for more than each low-income patient day
`
`included in the Medicaid fraction. So, to use an overly simplified exam-
`
`
`ple, a hospital with 100 of the former will get a larger rate adjustment
`than a hospital with 100 of the latter. Although Congress did not explain
`
`that difference, it presumably reflects the Medicare-centric perspective
`of what is, after all, a Medicare payment scheme. (The Medicaid statute
`
`separately requires States to make DSH payments, using a different for-
`
`mula that focuses on a hospital’s Medicaid population. See 42 U. S. C.
`§1396r–4. But that statutory provision is not at issue here.)
`
`
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`
`
`

`

`6
`
`
`BECERRA v. EMPIRE HEALTH FOUNDATION, FOR
`VALLEY HOSPITAL MEDICAL CENTER
`
`Opinion of the Court
`policy runs dry. Limits like those prompt the question pre-
`sented here: Are patients whom Medicare insures but does
`
`not pay for on a given day “entitled to [Medicare Part A]
`benefits,” for purposes of computing a hospital’s dispropor-
`
`tionate-patient percentage? §§1395ww(d)(5)(F)(vi)(I–II).
`
`An HHS regulation, issued in 2004, says those patients
`remain so entitled. See 69 Fed. Reg. 48916. Under the reg-
`ulation, whether Medicare is actually paying for a patient’s
`hospital treatment is irrelevant. So, for example, it does
`not matter that a patient has exhausted his 90 days of cov-
`erage for an illness, or that a private insurer is paying for
`his hospital stay. As long as the patient meets the basic
`statutory criteria for Medicare (i.e., he is over 65 or disa-
`
`bled), then the patient counts in the denominator and, if he
`is poor, in the numerator of the Medicare fraction (as “enti-
`tled to [Medicare Part A] benefits”). See id., at 49098–
`49099. And by the same token, he does not count in the
`numerator of the Medicaid fraction (which includes only
`those “not entitled to [Medicare Part A] benefits”). See ibid.
`As HHS explained in 2004, the effect of the regulation var-
`ies depending on the makeup of a hospital’s patient popula-
`tion. See ibid. But for most hospitals, the regulation has
`worked to decrease DSH payments, because as beneficiar-
`
`ies are added to the Medicare fraction’s denominator (even
`though poor beneficiaries are also added to its numerator),
`
`a hospital’s Medicare fraction generally (though not always)
`goes down. See Letter from E. Prelogar, Solicitor General,
`to S. Harris, Clerk of Court (Nov. 23, 2021).
`
`Respondent Empire Health Foundation challenged the
`regulation as inconsistent with the statutory fraction de-
`scriptions, and the Court of Appeals for the Ninth Circuit
`agreed. See Empire Health Foundation v. Azar, 958 F. 3d
`873 (2020). The court focused on the statute’s use of two
`different phrases: “entitled to [Medicare Part A] benefits”
`and (in the Medicaid fraction alone) “eligible for [Medicaid]
`
`assistance.” Id., at 885. Relying on Circuit precedent, the
`
`
`
`

`

`7
`
`
`Cite as: 597 U. S. ____ (2022)
`
`Opinion of the Court
`court read the latter, “eligible” phrase to “mean that a pa-
`tient simply meets the Medicaid statutory criteria”—re-
`gardless of whether “Medicaid actually paid” for a given ser-
`vice on a given day. Ibid. That approach, of course, is
`
`
`analogous to the one the HHS regulation adopts for Medi-
`care beneficiaries. But the Ninth Circuit reasoned that the
`statutory language relating to Medicare is different: It asks
`
`whether a person is “entitled to” (not “eligible for”) benefits.
`And the word “entitled,” the court held (relying on the same
`precedent), “mean[s] that a patient has an ‘absolute right
`. . . to payment.’” Ibid. (ellipsis in original). So even if a
`
`patient is over 65, he is not “entitled to [Medicare Part A]
`
`benefits” within the meaning of the statute for any hospital
`stay, or part thereof, Medicare is not paying for.
`
`As the Ninth Circuit recognized, two other Courts of Ap-
`peals had deferred to HHS’s contrary view of the statute
`and upheld the regulation. See Metropolitan Hospital v.
`
`Department of Health and Human Servs., 712 F. 3d 248
`(CA6 2013); Catholic Health Initiatives Iowa Corp. v. Sebe-
`lius, 718 F. 3d 914 (CADC 2013). We granted certiorari to
`
`resolve the conflict. See 594 U. S. ___ (2021).2
`II
`
`HHS’s regulation correctly construes the statutory lan-
`
`guage at issue. The ordinary meaning of the fraction de-
`scriptions, as is obvious to any ordinary reader, does not ex-
`actly leap off the page. See Catholic Health Initiatives, 718
`
`F. 3d, at 916 (The “language is downright byzantine”). The
`provisions are technical: They call to mind Justice Frank-
`furter’s injunction that when a statute is “addressed to spe-
`cialists, [it] must be read by judges with the minds of the
`specialists.” Some Reflections on the Reading of Statutes,
`47 Colum. L. Rev. 527, 536 (1947). But when read in that
`
`——————
`2This case does not raise the question whether HHS has properly in-
`terpreted the phrase “entitled to [SSI] benefits” in the Medicare fraction.
`Accordingly, we express no view on that issue.
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`8
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`BECERRA v. EMPIRE HEALTH FOUNDATION, FOR
`VALLEY HOSPITAL MEDICAL CENTER
`
`Opinion of the Court
`suitable way, the fraction descriptions disclose a surpris-
`ingly clear meaning—the one chosen by HHS. The text and
`context support the agency’s reading: HHS has interpreted
`the words in those provisions to mean just what they mean
`
`throughout the Medicare statute. And so too the structure
`
`of the DSH provisions supports HHS: Counting everyone
`who qualifies for Medicare benefits in the Medicare frac-
`tion—and no one who qualifies for those benefits in the
`
`Medicaid fraction—accords with the statute’s attempt to
`capture, through two separate measurements, two different
`
`segments of a hospital’s low-income patient population.
`A
`Speaking of twos, Empire’s textual argument also has a
`
`
`bifurcated structure—but neither part can produce its de-
`sired result. Empire primarily contends, echoing the Ninth
`
`Circuit, that “different words [mean] different things” when
`
`used in a single statute—and so “entitled” means some-
`thing different from “eligible.” Brief for Respondent 22. To
`
`be “eligible” for a benefit, Empire says, is to be “qualified”
`to seek it; to be “entitled” to a benefit means instead to have
`
`an “absolute right” to its payment. Id., at 4, 30. But that
`
`reading, even if plausible in the abstract, does not work in
`
`
`the Medicare statute. There, “entitled to benefits” is essen-
`tially a term of art, used over and over to mean qualifying
`(or, yes, being eligible) for benefits—i.e., being over 65 or
`
`disabled. And in the end, Empire basically concedes that
`point. It must devise a way to give “entitled to benefits” a
`
`different meaning in the fraction descriptions than the
`
`phrase has everywhere else in the Medicare law. See Tr. of
`Oral Arg. 37–41. So Empire shifts gears, relying now on
`
`the parenthetical phrase “(for such days)” to do its work—
`to transform the usual statutory meaning of “entitled to
`
` See ibid.;
`benefits” to something different and novel.
`§1395ww(d)(5)(F)(vi)(I) (“patients who (for such days) were
`
`entitled to [Medicare Part A] benefits”). (The dissent, for
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`

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` Cite as: 597 U. S. ____ (2022)
`
`Opinion of the Court
`its part, focuses most of its energies on this latter stage of
`Empire’s argument.) But those three little words do not ac-
`
`complish what Empire would like, having the much less
`
`radical function of excluding days of a patient’s hospital
`stay before he qualifies for Medicare (e.g., turns 65). So con-
`trary to Empire’s claim, being “entitled” to Medicare bene-
`fits still means—in the fraction descriptions, as throughout
`the statute—meeting the basic statutory criteria, not actu-
`ally receiving payment for a given day’s treatment.
`1
`
`First and foremost, the Medicare statute explicitly iden-
`tifies which individuals are “entitled to hospital insurance
`benefits under part A”—all people who meet the basic stat-
`utory criteria. §§426(a)–(b). “Every individual,” the law
`states, who “has attained age 65” and is entitled to ordinary
`
`social security payments “shall be entitled to” Medicare
`Part A benefits. §426(a). So too, “every individual” under
`age 65 who has been entitled to federal disability benefits
`
`for at least 24 months “shall be entitled” to Medicare Part
`
`A benefits. §426(b). The “[e]ntitlement to hospital insur-
`
`ance benefits” (as the section caption reads) is “automatic”:
`Age or disability makes a person “entitled” to Part A bene-
`
`fits without an application or anything more. §426; Hall v.
`
`Sebelius, 667 F. 3d 1293, 1294–1296 (CADC 2012). Turn 65
`
`or receive disability benefits for 24 months, and you have
`an entitlement to Part A benefits—because the latter is, ac-
`cording to the statute, simply a legal status arising from the
`
`former.3
`——————
` 3Another way of putting the point is to say that the Medicare statute
`
`uses the term “entitled” to benefits in the same way as the Medicaid stat-
`ute uses the term “eligible” for benefits. Compare 42 U. S. C. §426 (“en-
`titled” in Medicare context) with, e.g., §§1396, 1396d (“eligible” in Medi-
`caid context). That difference in overall statutory terminology is
`mirrored in the fraction provisions—“entitled to [Medicare Part A] bene-
`
`fits” and “eligible for [Medicaid] assistance.” §§1395ww(d)(5)(F)(vi)(I–II).
`As the D. C. Circuit put the point: “Congress has, throughout the various
`
`9
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`10
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`
`BECERRA v. EMPIRE HEALTH FOUNDATION, FOR
`
`VALLEY HOSPITAL MEDICAL CENTER
`Opinion of the Court
`That broad meaning of “entitlement” coexists with limi-
`
`tations on payment, as several statutory provisions show.
`
`The entitlement to benefits, the statute repeatedly says, is
` an entitlement to payment under specified conditions. To
`
`quote one provision: “entitlement of an individual” to Med-
`icare Part A benefits “consist[s] of entitlement to have pay-
`ment made under, and subject to the limitations in, part A.”
`§426(c)(1); see §1395d(a) (similarly stating that the entitle-
`ment to benefits entails the receipt of “payment[s] . . . sub-
`ject to the provisions of this part”). Those limits on payment
`
`include, as described earlier, the 90-day hospital-stay cap.
`
`See supra, at 5–6. And indeed the statute twice refers to
`patients who are “entitled to benefits under part A but
`ha[ve] exhausted benefits for inpatient hospital services.”
`§§1395l(a)(8)(B)(i), 1395l(t)(1)(B)(ii). Under Empire’s read-
`ing, that statement makes no sense: A patient is not, Em-
`pire argues, “entitled to benefits” when the statute pre-
`
`cludes payment. See supra, at 8. But the statute says
`otherwise. It considers those who have exhausted their cov-
`
`erage (and so cannot receive further payments for a hospital
`stay) still “entitled to [Part A] benefits.”
`
`
`In thus describing the Part A entitlement, the Medicare
`statute reflects the complexity of health insurance. Con-
`
`sider your own health plan (maybe it is Medicare). You
`might have hit some limit on coverage as to one medical
`service—let’s say, eye care. But you’re still insured: Your
`policy will pay for more eye care in the next coverage period
`
`and meanwhile will pay for your knee replacement. So it is
`with Medicare Part A. As the 2004 regulation explains, pa-
`
`tients “who have exhausted their Medicare Part A inpatient
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`coverage may still be entitled to other Part A benefits.” 69
`——————
`Medicare and Medicaid statutory provisions, consistently used the words
`‘eligible’ to refer to potential Medicaid beneficiaries and ‘entitled’ to refer
`
`to potential Medicare beneficiaries.” Northeast Hospital Corp. v. Sebe-
`lius, 657 F. 3d 1, 12 (2011). Congress simply followed suit when referring
`to the two programs in the fraction provisions.
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` 11
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` Cite as: 597 U. S. ____ (2022)
`
`Opinion of the Court
` Fed. Reg. 49098. Medicare Part A also covers, “for example,
`
`certain physician services and skilled nursing services” out-
`side the hospital setting. See CMS–1498–R, at 10. And
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`even as to hospital care, another 90 day