The Deficit Reduction Act of 2005 is a United States Act of Congress concerning the federal budget that became law in 2006. Legislative history The Senate's version passed after a tie-breaking vote was cast by Vice President Dick Cheney. The bill passed the chamber with all Democrats and five Republicans voting against the bill. The House version passed by a vote of 217-215, with all Democrats, fourteen Republicans, and one Independent voting against. The Senate bill was signed by President George W. Bush on February 8, 2006. Dispute over legal status A dispute arose over whether both houses of Congress had approved the same bill. As argued by Public Citizen in a lawsuit over the Act, the Senate clerk had mistakenly changed a clause related to Medicare reimbursements when transmitting the engrossed bill to the House. So when the House voted to accept the Senate's version of the bill, the House clerk had different text than the Senate had approved. When the bill was returned to the Senate the clerk there restored the text as previously voted on by the Senate. That version was signed by the presiding officers of Congress and by the President. Many argued that the document signed by the President did not have the force of law because the enacting process bypassed the Bicameral Clause of the U.S. Constitution. For example, Representative Henry Waxman (D-CA) wrote a letter to Minority Leader (later Speaker) Nancy Pelosi on February 14, 2006 saying three experts he consulted (Professor Gerhardt, Professor Dorf, Professor Raskin) said the law was clearly unconstitutional. At least five individuals or organizations sued to overturn the act, or parts of it they disagreed with, including Public Citizen, attorney James Zeigler, and education finance company OneSimpleLoan. Congressional leaders and administration officials cited the enrolled bill rule in defense of the Act. An 1892 Supreme Court case, Field v. Clark () said disputes over differing versions of a bill that were certified by both chambers were not for the courts to decide. All courts to consider the question, including the Federal District Court of Eastern Michigan in Conyers v. Bush, ruled that the Act was valid notwithstanding the controversy or that opponents did not have standing to sue. The Supreme Court declined invitations to reconsider or overrule the enrolled bill rule. The difference between the two versions is the provision regarding the length of time that Medicare would