Health is not an absolute condition, but is assessed by reference to age and other factors. Therefore, a relative scale is necessary to determine whether an elderly person’s right to health care is being satisfied. Today, older Americans are increasingly affected by the growing need to regulate health care delivery. Since 1900, those over the age of 85 years have become twenty-one times as numerous in society, with an eightfold increase in the number of people over the age of 65. Given the need to curb rising health care costs — particularly the expenses related to caring for older individuals — and improve access to health care, society has effectuated two methods of governing the distribution of limited health care resources: allocation and rationing.
George P. Smith, II, Allocating Health Care Resources to the Elderly, 1 ELDER L. REV. 9 (2002).