Daley v. Sudders

33 Mass. L. Rptr. 150
CourtMassachusetts Superior Court
DecidedDecember 24, 2015
DocketNo. WOCV201500188D
StatusPublished

This text of 33 Mass. L. Rptr. 150 (Daley v. Sudders) is published on Counsel Stack Legal Research, covering Massachusetts Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daley v. Sudders, 33 Mass. L. Rptr. 150 (Mass. Ct. App. 2015).

Opinion

Curran, Dennis J., J.

The Office of Medicaid denied James Daley’s application for long-term Medicaid benefits, and his wife, Mary Daley, acting as his Personal Representative, appeals that decision.

The Office of Medicaid, known as MassHealth because it administers the Massachusetts Medicaid program (see G.L.c. 118E, §9A), falls under the authority of the Secretary of the Executive Office of Health and Human Services. (See G.L.c. 6A, §§16, 16B.) Mrs. Mary Daley, acting as the Personal Representative of her husband James Daley’s estate, brings this action for judicial review of MassHealth’s decision under G.L.c. 30A, §14. Mrs. Daley has moved for judgment on the pleadings to vacate MassHealth’s decision. A hearing has been held on that motion.

For the following reasons, Mrs. Daley’s motion for judgment on the pleadings must be DENIED.

BACKGROUND

Judicial review of an agency decision is confined to the administrative record. G.L.c. 30A, §14(4), (5). The record before MassHealth contained the following facts. Over eight years ago, on December 19,2007, Mr. and Mrs. Daley established the “James Daley and Mary Daley Irrevocable Trust’ and appointed their son James Daley and their daughter Patricia Tubaj as its trustees. (The trust’s applicable provisions are discussed below.)

That same day, Mr. and Mrs. Daley conveyed their interest in their condominium located at 215 Mill Street, Unit 103 in Worcester to the Trust. They retained life estates under the property’s deed and continued to live there together for about six years until health reasons required that Mr. Daley be admitted to the Millbury Health Care Center on December 20, 2013.

On February 21, 2014, Mr. Daley applied for long-term care Medicaid benefits effective January 19, 2014.3 On April 14, 2014, MassHealth denied Mr. Daley’s application after it concluded that his assets exceeded Medicaid’s $2,000 eligibility limit. MassH-ealth determined he was financially ineligible for benefits because his assets included the Trust’s principal, valued at $150,943. The Trust’s principal was the value of the Daleys’ condominium. Mr. Daley appealed that decision to the Office of Medicaid Board of Hearings.

After a hearing, the Office of Medicaid Board of Hearings affirmed MassHealth’s determination in a decision dated October 22, 2014. The Board counted the Trust’s principal as an asset because (1) Mr. and [151]*151Mrs. Daley’s deed explicitly reserved their right to occupy and use the condominium; and (2) their Trust granted them the right to convert the Trust’s principal into income.

Mr. Daley died on November 13, 2014—about seven years after establishing the Trust. Mrs. Daley then filed a request for a rehearing, which the Board denied for failure to show good cause. On February 11, 2015, Mrs. Daley filed a complaint seeking judicial review of MassHealth’s decision under G.L.c. 30A, arguing that she and her husband were essentially indigent and eligible for public benefits because their assets are held by an irrevocable trust. On October 15,2015, Mrs. Daley filed this motion for judgment on the pleadings. MassH-ealth filed its opposition motion, contending that the Daleys were financially ineligible for Medicaid benefits. Mrs. Daley continues to live at the condominium.

DISCUSSION I. Standard of Review

Under G.L.c. 30A, §14(7), this court must uphold MassHealth’s decision unless it is unsupported by substantial evidence, is arbitrary or capricious, constitutes an abuse of discretion, or is otherwise not in accordance with the law. See eVineyard Retail Sales-Mass., Inc. v. Alcoholic Bevs. Control Comm’n, 450 Mass. 825, 828 (2008). This court “must apply all rational presumptions in favor of the validity of the administrative action and not declare it void unless its provisions cannot by any reasonable construction be interpreted in harmony with the legislative mandate.” Thomas v. Commissioner of the Div. of Med. Assistance, 425 Mass. 738, 746 (1997) (citation omitted). Moreover, this “court will not substitute its own judgment concerning the penalty the [agency] imposes.” Kobrun v. Bd. of Registration in Med., 444 Mass. 837, 842 (2005) (citation omitted). Consequently, as a matter of law, as the party appealing MassHealth’s decision, Mrs. Daley bears the heavy burden of demonstrating the decision’s invalidity. See Ten Local Citizen Group v. New Eng. Wind, LLC, 457 Mass. 222, 228 (2010) (internal quotation and citation omitted).

This court gives substantial deference to an agency’s interpretation of those statutes with which it is charged with enforcing This is “(e]specially [ ] so when the case involves interpretation of a complex statutory and regulatory framework such as Medicaid.” Shelales Dir. of the Office of Medicaid, 75 Mass.App.Ct. 636, 640 (2009) (citation omitted). Deference is particularly appropriate when the statute in question grants broad rule-making authority to the agency, contains an ambiguity or gap, or broadly sets out a legislative policy that must be interpreted by the agency." Souza v. Registrar of Motor Vehicles, 462 Mass. 227, 229 (2012) (citations omitted).

II. Analysis

The Massachusetts Medicaid program, MassHealth, “is a joint [s]tate and [flederal program designed to pay the cost of medical care for those who are otherwise unable to afford it.” Normand v. Dir. of the Office of Medicaid, 77 Mass.App.Ct. 634, 636 (2010) (citations omitted). See also 130 Code of Massachusetts Regulations section 515.002(A).4 “Because MassHealth is ajoint [flederal and [s]tate program, the Massachusetts statutes and regulations governing the program must be consistent with the requirements of [flederal [Medicaid] law.” Normand, 77 Mass.App.Ct. at 637 n.8. Consequently, as required by federal law, MassHealth applicants must meet certain financial eligibility requirements to qualify for benefits. Tarin v. Commissioner of Div. of Med. Assistance, 424 Mass 743, 747 (1997).

MassHealth provides nursing home benefits in the form of long-term care coverage for individuals who have $2,000 or less in “countable assets.” 130 Code of Massachusetts Regulations §§519.006(A)(2) and 520.003(A)(1).5 “Countable assets are all assets that must be included in a determination of [Medicaid] eligibility.” 130 Code of Massachusetts Regulations §520.007. Here, it is undisputed that Mr. and Mrs. Daley are financially ineligible for MassHealth benefits if the Trust is considered a countable asset. This court is constrained to conclude that the Office of Medicaid Board of Hearings correctly determined that the Daleys’ Trust was a countable asset because (1) their condominium property remained available for their use after they deeded it to the Trust; and (2) they had the right to condominium-generated income (a situation here that was theoretical only). Both grounds are addressed below.

A. Availability of Properly

Property held in an irrevocable trust is a countable asset where it is “available according to the terms of the trust[.]” 130 Code of Massachusetts Regulations section 520.023(C)(1)(d). If a Medicaid applicant can use and occupy her home as a life tenant, then her home is “available.” See Doherty v. Dir. of the Office of Medicaid, 74 Mass.App.Ct. 439, 441 (2009) (home was available because applicant retained the right to reside there during her lifetime).

This court concludes that Mr.

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Related

Thomas v. Commissioner of Division of Medical Assistance
425 Mass. 738 (Massachusetts Supreme Judicial Court, 1997)
Lebow v. Commissioner of the Division of Medical Assistance
433 Mass. 171 (Massachusetts Supreme Judicial Court, 2001)
Guerriero v. Commissioner of the Division of Medical Assistance
745 N.E.2d 324 (Massachusetts Supreme Judicial Court, 2001)
Kobrin v. Board of Registration in Medicine
832 N.E.2d 628 (Massachusetts Supreme Judicial Court, 2005)
eVineyard Retail Sales-Massachusetts, Inc. v. Alcoholic Beverages Control Commission
882 N.E.2d 334 (Massachusetts Supreme Judicial Court, 2008)
Ten Local Citizen Group v. New England Wind
457 Mass. 222 (Massachusetts Supreme Judicial Court, 2010)
Souza v. Registrar of Motor Vehicles
967 N.E.2d 1095 (Massachusetts Supreme Judicial Court, 2012)
Doherty v. Director of the Office of Medicaid
908 N.E.2d 390 (Massachusetts Appeals Court, 2009)
Shelales v. Director of the Office of Medicaid
915 N.E.2d 1092 (Massachusetts Appeals Court, 2009)
Normand v. Director of the Office of Medicaid
933 N.E.2d 658 (Massachusetts Appeals Court, 2010)

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Bluebook (online)
33 Mass. L. Rptr. 150, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daley-v-sudders-masssuperct-2015.