Flachs v. Illinois Department of Human Services

2021 IL App (4th) 200349-U
CourtAppellate Court of Illinois
DecidedAugust 20, 2021
Docket4-20-0349
StatusUnpublished
Cited by2 cases

This text of 2021 IL App (4th) 200349-U (Flachs v. Illinois Department of Human Services) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Flachs v. Illinois Department of Human Services, 2021 IL App (4th) 200349-U (Ill. Ct. App. 2021).

Opinion

NOTICE 2021 IL App (4th) 200349-U This Order was filed under FILED Supreme Court Rule 23 and is August 20, 2021 NO. 4-20-0349 not precedent except in the Carla Bender limited circumstances allowed 4th District Appellate under Rule 23(e)(1). IN THE APPELLATE COURT Court, IL

OF ILLINOIS

FOURTH DISTRICT

ALBERTA FLACHS, by Her Attorney in Fact, ) Appeal from the LOWELL A. FLACHS, ) Circuit Court of Plaintiff-Appellant, ) Adams County v. ) No. 19MR117 THE ILLINOIS DEPARTMENT OF HUMAN ) SERVICES, and GRACE HOU, in Her Official Capacity ) Honorable as Secretary of Human Services, ) Scott D. Larson, Defendants-Appellees. ) Judge Presiding.

JUSTICE HARRIS delivered the judgment of the court. Justices Turner and Cavanagh concurred in the judgment.

ORDER

¶1 Held: Plaintiff forfeited review of her claim challenging the sufficiency of the notice issued by the Department of Human Services following its decision to deny her application for welfare benefits. The Department of Human Services did not violate federal or state regulations or plaintiff’s right to due process in denying plaintiff’s request to reopen her application for welfare benefits.

¶2 In September 2017, plaintiff, Alberta Flachs, filed an application for Medicaid

benefits to help cover her long-term-care expenses. On March 3, 2018, defendant, the Illinois

Department of Human Services (the Department), denied plaintiff’s application because she failed

to submit certain information to verify her eligibility for benefits. Five days later, Lowell Flachs,

acting as plaintiff’s power of attorney, requested the Department reopen plaintiff’s application and

submitted documents to the Department that he believed demonstrated plaintiff’s eligibility for

benefits. On January 9, 2019, the Department denied plaintiff’s request to reopen her application. Plaintiff filed an administrative appeal, which was dismissed for lack of jurisdiction. Plaintiff then

sought administrative review in the trial court, and the court affirmed the Department’s dismissal.

¶3 On appeal, plaintiff argues the Department’s March 3, 2018, notice of decision and

the Department’s denial of her request to reopen her Medicaid application did not comply with

requirements set forth in federal regulations and the Illinois Administrative Code and denied her

due process. We affirm.

¶4 I. BACKGROUND

¶5 Plaintiff is a resident of Sunset Home, a long-term care facility located in Quincy,

Illinois. On September 15, 2017, plaintiff applied for medical assistance through Medicaid to help

cover her long-term care expenses.

¶6 On September 22, 2017, the Department sent plaintiff and Sunset Home a document

titled “Instructions to Client,” which stated that, to confirm her eligibility for medical benefits,

plaintiff was required to submit: (1) statements relating to her banking and other financial

accounts, (2) a prepaid burial contract, if she had one, (3) if applicable, verification that her burial

expenses were funded by her life insurance policy, (4) information related to a vehicle she owned,

(5) information related to any property she owned which had been sold or given away, (6) copies

of her health insurance cards, (7) proof of any power of attorney, and (8) a Department form to be

filled out. The Instructions to Client document further stated: “If we do not hear from you by

[October 2, 2017], we will not be able to decide if you qualify and your application may be denied.”

¶7 On February 6, 2018, the Department sent plaintiff, Sunset Home, and Lowell

Flachs a document titled “Verification Checklist” requesting: (1) bank statements from plaintiff’s

checking account covering certain periods, (2) verification of a certain life insurance policy or

annuity referenced in a checking account statement plaintiff had previously submitted, (3) a

-2- pension statement covering a certain period, (4) information related to the sale of her vehicle, and

(5) the “origin of deposits over $500 made into [plaintiff’s] checking acc[ount].” The checklist

also stated: “If you do not respond by Feb[ruary] 16, 2018, your SNAP, Cash and/or Medical

benefits could be reduced, cancelled, or denied.”

¶8 The record does not indicate that plaintiff or anyone acting on her behalf submitted

any documents to the Department in response to the February 6, 2018, verification checklist prior

to February 16, 2018.

¶9 On March 3, 2018, the Department sent plaintiff, Sunset Home, and Lowell a notice

of decision denying her application for medical assistance (the Notice). The Notice stated:

“This is the decision made about your application for Medical Assistance

dated September 15, 2017.

DENIED—per Policy Manual Chapter PM 02-07

Explanation:

Your eligibility cannot be determined due to your failure to provide

necessary information.

If your application is denied, you may meet with staff at the local

[Department] Family Community Resource Center *** to ask questions about the

denial. At this informal meeting, you may present information or evidence you

think is important to the decision and you may bring individuals of your choice to

represent you. The action explained in this notice will not be taken if you can show

it is wrong.

Whether you choose to meet or not, you have the right to appeal the denial

of your application.

-3- ***

If you do not agree with this decision, you have the right to appeal and

receive a fair hearing. You must file the appeal within 60 days after the Date of

Notice (see page 1 of this notice). You may represent yourself at this hearing or

may be represented by anyone else you choose such as a lawyer, relative or friend.”

The Notice also explained how to request an appeal of the Department’s decision and listed

resources for free legal assistance.

¶ 10 Five days later, on March 8, 2018, Lowell, acting as plaintiff’s power of attorney,

sent the Department an email which stated, “I would like to request that this case be reopened for

Alberta E. Flachs ***[.] Attached are documents that you asked for along with a letter stating why

we were late in getting the paperwork into you.” In the email, Lowell included documents related

to plaintiff’s life insurance policy, bank accounts, prepaid burial contract, vehicle, and annuity.

Immediately thereafter, the Department responded, stating, “Your email inquiry has been

forwarded for case reopen review. Thank you for your patience.”

¶ 11 On January 9, 2019, the Department contacted Sunset Home by telephone and

informed a representative of the facility that the Department had denied plaintiff’s request to

reopen her application and that plaintiff’s application for benefits remained denied. The

Department did not otherwise contact plaintiff, Lowell, or Sunset Home regarding plaintiff’s

request to reopen her application.

¶ 12 On January 24, 2019, plaintiff filed an administrative appeal with the Department’s

Bureau of Hearings. On the appeal request form, plaintiff’s authorized representative indicated

that plaintiff was appealing the “Denial of Re-open conveyed by phone call on or about 1-9-19”

and that she requested a fair hearing because “[her] application/request was denied and [she]

-4- disagree[d] with this.” During the first hearing on plaintiff’s appeal, plaintiff’s representative

argued the Department’s failure to provide written notice of its decision not to reopen plaintiff’s

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Related

Thompson v. Department of Human Services
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2024 IL App (1st) 221002 (Appellate Court of Illinois, 2024)

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