Washington State Dept. of Social and Health Servs. v. Guardianship Estate of Keffeler, 537 U.S. 371, 17 (2003)

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Cite as: 537 U. S. 371 (2003)

Opinion of the Court

those regulations as allowing reimbursement by a representative payee for maintenance costs, at least for costs incurred after the first benefit payment is made to the payee. Cf. POMS GN 00602.030 (defining a "past debt," which may be satisfied only if a beneficiary's current and reasonably foreseeable needs are met, as "a debt the beneficiary incurred before the date of the first benefit payment is made to the current payee").9

The Government has gone even further to support this as a reasonable interpretation, text aside, owing to significant advantages of the reimbursement method in providing accurate documentation and allowing for easy monitoring of representative payees in administering Social Security. See Brief for United States as Amicus Curiae 28-29.10 In fact,

it would be hard not to see this type of slightly delayed reimbursement as the only way OASDI funds could be spent on a foster child's current maintenance, since the Administration disburses those Social Security benefits with a time lag. See POMS GN 02401.001 (noting that OASDI benefits are dispensed within the month after they are due). In short, the Commissioner's interpretation of her own regulations is

9 There is one exception to this rule, although it is not relevant for our present purposes. In October 1996, Congress amended 42 U. S. C. § 1383 to specify that when the Administration issues a retroactive lump sum payment of SSI benefits that exceeds six times the monthly benefit amount, that amount is to be deposited directly into a dedicated interest-bearing bank account to be used only for certain special needs. § 1383(a)(2)(F).

10 Moreover, as the Government notes, the position of the Supreme Court of Washington and respondents is ultimately "one of empty formalism" because a State could, indisputably, use a foster child's Social Security benefits directly for the costs of care and then reduce the State's own funding by the same amount. Brief for United States as Amicus Curiae 28. The financial result would be the same as in the system currently used by the department, yet the practical advantages of the reimbursement method of accounting would be lost.

387

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