- 15 - Whether payments for services are considered benefits appears an open question, though at least The American Heritage Dictionary of the English Language supports that view. Dictionary definitions of the term “benefit” do not allow us to eliminate from the meaning of the term “payments received in connection with the performance of services” (as respondent implicitly argues). We next look to see whether Congress understood the term “benefit” to include a payment of the sort at issue here. D. Context While the titles of statutes and statutory headings cannot limit the plain meaning of statutory text, they are of some use for interpretative purposes when they shed some light on ambiguous words or phrases. Bhd. of R.R. Trainmen v. B&O R.R. Co., 331 U.S. 519, 528-529 (1947). Title 38 (2000) is entitled “VETERANS’ BENEFITS”. Section 1718 falls within the following subdivisions of title 38: part II, “GENERAL BENEFITS”; chapter 17, “HOSPITAL, NURSING HOME, DOMICILIARY, AND MEDICAL CARE”; and subchapter II, “HOSPITAL, NURSING HOME, OR DOMICILIARY CARE AND MEDICAL TREATMENT”. As stated, section 1718 is entitled “Therapeutic and rehabilitative activities”. As pertinent to the statutory hierarchy, section 1718 therapeutic work programs clearly fall within the ambit of medical benefits (medical care and medical treatment) provided to veterans. Distributions from the VA Special Therapeutic andPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: November 10, 2007