Crammer v. Department of Public Welfare

3 Pa. Commw. 460, 1971 Pa. Commw. LEXIS 373
CourtCommonwealth Court of Pennsylvania
DecidedNovember 19, 1971
DocketAppeal No. 39 C. D. 1971
StatusPublished
Cited by1 cases

This text of 3 Pa. Commw. 460 (Crammer v. Department of Public Welfare) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Crammer v. Department of Public Welfare, 3 Pa. Commw. 460, 1971 Pa. Commw. LEXIS 373 (Pa. Ct. App. 1971).

Opinion

Per Curiam

After argument before a panel and reargument before the Court en banc, the Court being equally divided, the adjudication is hereby affirmed.

President Judge Bowman

Opinion of in Support of Affirming Adjudication of Department of Welfare :

The Federal statutory court convened in Fullington v. Shea, 320 F. Supp. 500 (D. Colo. 1970) in my opinion correctly interpreted the Federal statutory law involved in this appeal, and it is not here disputed that the Department’s controlling regulation is consistent with the applicable Pennsylvania statutory law.

Judges Wilkinson and Rogers join in this opinion.

Judge Crumlish, Jr.,

Opinion of in Support of Reversal :

Edna F. Crammer, appellant, is just one of a multitude of Social Security payment recipients all across the United States who have experienced an unfortunate and unexpected effect of a nationwide increase in the allotment of Social Security benefits. Prior to the increase, appellant’s Social Security monthly benefits, her sole income, were less than the maximum monthly income allowance of the Pennsylvania Department of Public Welfare. Therefore, she was classified as “categorically needy” and was eligible to receive medical benefits including the payment of costs for drugs. This care was provided by the State under the mandate of the Social Security Act, 42 U.S.C.- §§301 et seq. However when the Social Security payments increased, appellant’s income became greater than the permissible maximum for public assistance, and she then received medical benefits under an optional state plan which does not provide for medicinal payments. As a result, instead of receiving $95.00 per month and having her [463]*463drugs paid for, she was receiving $115.00 per month and paying out of this allotment an average of $60.00 per month for drugs.

The Social Security Act, supra, provides that the states, in conjunction with the Federal government, will provide medical care to the “categorically needy.” This group includes those persons whose incomes are below the maximum welfare level. A second plan, optional with the states, provides medical care for persons with incomes above that level. Pennsylvania has adopted the second plan but medicinal payments are not included as in the required plan.

Appellant urges us to direct the Department to reinstate her under the all encompassing plan, advancing four arguments in support of her position.

First, it is suggested that the Social Security Act, Section 1396a(a) (17) (D) mandates that tests of eligibility in state programs allow for flexibility of income caused by heavy medical expenses. This is the so-called “spend-down” test in which necessary medical expenses would be deducted from income prior to determining eligibility.

Second, appellant argues that the Department of Public Welfare Manual mandates that her drug expenses be included in living expenses- when computing whether her living expenses exceed her income for eligibility as “categorically needy” for non-money payments.

Third, appellant contends that the classification of “categorically needy” and “medically needy” based upon income is unreasonable and arbitrary in contravention of her right of equal protection of the law guaranteed by the Fourteenth Amendment to the United States Constitution.

Finally, she says that the refusal of the State to grant her access to her federally guaranteed rights under the Social Security Act, as alleged in her first argu[464]*464xnent, denies her due process of law in contravention of the Fourteenth Amendment.

The first issue raised by appellant was discussed at length by the United States District Court for the District of Colorado in Fullington v. Shea, 320 F. Supp. 500 (D. Colo. 1970), a case involving similar facts.

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Related

Crammer v. Commonwealth
296 A.2d 815 (Supreme Court of Pennsylvania, 1972)

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Bluebook (online)
3 Pa. Commw. 460, 1971 Pa. Commw. LEXIS 373, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crammer-v-department-of-public-welfare-pacommwct-1971.