Arkansas v. Charles Gresham, et al.
AdministrativeLaw SocialSecurity Securities JusticiabilityDoctri
Whether the Secretary's approval of the Arkansas Works Amendment was lawful
QUESTION PRESENTED The Social Security Act authorizes the Secretary of Health and Human Services to approve “any experimental, pilot, or demonstration project which, in the judgment of the Secretary, is likely to assist in promoting the objectives” of a host of state-administered welfare programs including Medicaid. Here, Arkansas sought approval to test the hypothesis that conditioning Medicaid expansion benefits on work, education, or volunteering would lead to healthier outcomes for its beneficiaries. The Secretary agreed, predicting that Arkansas’s proposal would likely improve beneficiary health and promote independence from governmental support. On review, the United States Court of Appeals for the D.C. Circuit held that approval unlawful. It did not hold that the Secretary’s prediction of health benefits was unreasonable, or even that the Secretary failed to weigh those benefits against the project’s potential costs. Rather, it held the Secretary could not even consider them because, in its view, the objective of Medicaid is expanding the ranks of those on Medicaid and beneficiary health is beyond the Secretary’s remit. The question presented is: Whether the Secretary’s approval of the Arkansas Works Amendment was lawful. (i)