Barone v. Department of Human Services

STEIN, J.,

dissenting.

The majority opinion’s thesis for sustaining legislative and administrative restrictions on pharmaceutical assistance to disabled persons is uncomplicated and inviting. According to the majority, restricting such assistance only to those disabled persons receiving disability benefits under the Social Security Act is constitutional because it is rational, and it is rational because it “eliminates the State’s need to conduct individual disability determinations and thereby * * * furthers the legitimate interest of minimizing administrative costs * * *.” Ante at 364.

The problem with the majority’s analysis is that it applies the rational basis test to the wrong group — those included in the PAAD program. Of course it is “rational” for government to limit a benefit program to a restricted group if to do so saves money and administrative effort. The question is whether, in the context of the purpose of the program, there is a rational basis for excluding those to whom the benefits have been denied. Tested by this inquiry and applying the rational basis test used by the majority, these restrictions on eligibility for pharmaceutical benefits cannot be sustained.

Thus, a preliminary question we must answer is who is ineligible for Social Security disability benefits — and why. The answer is found in the Social Security Act, 42 U.S.C. §§ 301-*3781397 (1983 & Supp.1987). A variety of services are excluded from the definition of “employment” covered by the Act, including some agricultural jobs and domestic positions, and certain services performed for federal agencies if covered by a federal retirement system. 42 U.S.C. § 410. Services performed in the employ of a state or a political subdivision of a state are also excluded unless social security coverage is provided pursuant to an agreement between the State and the Secretary of Health and Human Services. 42 U.S.C. §§ 410, 418. See generally A. Abraham and D. Kopelman, Federal Social Security, at 7-22 (1979) (discussing covered employment under the Social Security Act).

Thus, petitioner Lottie Adkins, who worked for the County of Essex at Overbrook Hospital for approximately thirty years until her retirement in 1979, does not receive Social Security disability benefits, but not because she is insufficiently disabled. She suffers from arteriosclerotic heart disease and rheumatic disease with severe orthopedic limitations. A privately-retained physician certified that her disabling conditions satisfy the SSDI standards. However, she is denied PAAD benefits because the employer who hired her in 1949 was excluded from participation in the Social Security program. The precise constitutional issue before us is whether, given the legislative purpose of the PAAD program, there is a rational basis for excluding Ms. Adkins, or persons similarly situated, because the employment she undertook years ago was excluded from coverage under the Social Security Act.

Petitioner Barone, certified as blind by the State Commission for the Blind and Visually Impaired under the same test for blindness that applies for SSDI benefits, never worked outside the home after the age of sixteen. The record is unclear whether this was due to her visual impairment or the responsibilities of raising her children, or both. In any event, since Social Security disability benefits depend on a required period *379of covered employment, Ms. Barone is plainly ineligible for SSDI. Assuming that she meets the SSDI test for disability, what rational basis — in the context of the legislative purpose of PA AD — can there be for denying her benefits?

The majority begs the question when it observes that the test for disability under the Social Security Act, “inability to engage in substantial gainful activity,” 42 U.S.C. § 416(i)(1), is different from the test imposed under other disability benefits programs. Ante at 370-371. There is no question that the legislature could, if it desired, adopt as its standard for disability that imposed by the Social Security Act. But it has not adopted that standard — or any other standard of disability — to test eligibility for pharmaceutical assistance. Instead, it has restricted eligibility to those disabled persons who both meet the SSDI standard and who, during their working lives, had employment that was covered by the Social Security Act.

The State of New Jersey has the right to grant or deny pharmaceutical benefits to disabled persons. If it grants such benefits, presumably on the basis that disabled persons have a greater need for pharmaceutical assistance than the rest of the population, it can impose such reasonable standards of eligibility as are consistent with the legislative purpose, taking into account the resources available for funding such benefits. It can rationally exclude from coverage under such a program persons insufficiently disabled to meet the legislative or regulatory standard. But it cannot rationally exclude disabled persons simply on the basis that during their working years they were not employed for a sufficient period by employers eligible for coverage under the Social Security Act. Such an exclusion, in the context of the purpose of pharmaceutical assistance benefits, does not serve a rational governmental purpose and therefore violates federal and state constitutional standards. Ranschburg v. Toan, 709 F.2d 1207 (8th Cir.1983); Greenberg v. Kimmelman, 99 N.J. 552, 567 (1985).