Hayman v. State, Department of Health & Welfare

604 P.2d 724, 100 Idaho 710, 1979 Ida. LEXIS 512
CourtIdaho Supreme Court
DecidedDecember 17, 1979
Docket12655
StatusPublished
Cited by6 cases

This text of 604 P.2d 724 (Hayman v. State, Department of Health & Welfare) is published on Counsel Stack Legal Research, covering Idaho Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hayman v. State, Department of Health & Welfare, 604 P.2d 724, 100 Idaho 710, 1979 Ida. LEXIS 512 (Idaho 1979).

Opinions

McFADDEN, Justice.

This is an appeal from an order reversing the decision of a hearing officer which terminated public assistance and medical assistance to Gordon and Esther Hayman. Subsequent to the hearing in the district court Mr. Hayman passed away and Mrs. Hayman appears on this appeal individually and as an heir of Mr. Hayman.

The Haymans, husband and wife, were elderly persons (71 and 73 years of age, respectively) and in ill health when the Idaho Department of Health and Welfare (herein Department), terminated their old age assistance and medical assistance payments. In 1976 they were notified that their various grants would be terminated because it was determined by the Department that, based upon an increase in federal Social Security benefits they were receiving, no “budget deficit” existed because their income exceeded the maximum level, set by Department regulation. The Hay-mans appealed from this termination of benefits, and, following a hearing, the Department hearing officer affirmed the termination. The Haymans then appealed to the district court, which reversed the decision of the hearing officer, finding that it was arbitrary, capricious and unreasonable for the Department to omit medical needs from a determination of old age assistance eligibility. The Department appealed to this court.

As stated by the Department, the issue presented by this appeal is whether the Department is required by Idaho Code Title 56, Chapter 2, to provide a “medically needy” program to all aged persons in the state regardless of the level of their income or their eligibility for categorical assistance and whether the Department has acted unreasonably in failing to adopt such a program. The Haymans expand this issue by arguing, as the district court held, that the Department was unreasonable and capricious in not including medical expenses in the computation of eligibility for old age assistance.

[712]*712For the reasons discussed in this opinion, it is the conclusion of this court that the trial court erred in its ruling and that its order must be reversed and the order of the Department’s hearing examiner reinstated.

State and federal matching funds for medical assistance provided by Title XIX of the federal social security act may be dispensed by the states through at least one of two programs. These have come to be known as “categorically needy” and “medically needy” programs. In “medically needy” programs, any person whose income and resources are insufficient to provide necessary medical services is entitled to receive medical assistance. In “categorically needy” programs the person in need of medical assistance must first qualify for one of the four varieties of public assistance, old age assistance, aid to dependent children, aid to the blind, or aid to the disabled. Only then may medical assistance be provided.

In Curtis v. Child, 95 Idaho 63, 501 P.2d 1374 (1972), the court held that Idaho had enacted a “medically needy” program. The statute which the court construed to reach its decision, I.C. § 56-209b, stated that medical assistance was to be available to persons in any of the four categories mentioned above, and also “to such other persons as may be defined under the authority of this act to be medically needy individuals.” Curtis, supra, 95 Idaho at 66, 501 P.2d at 1377. Since the decision in Curtis, 56-209b has been amended. At the time pertinent to this action it reads as follows:

“Medical assistance.—Medical assistance shall be awarded to persons who are recipients of old-age assistance, aid to dependent children, aid to the blind, aid to the permanently and totally disabled, and to such persons as mandated by title XIX of the Social Security Act . [am. 1973, ch. 161 § 2, p. 306]” (Emphasis added.)

Title XIX of the Social Security Act gives States the option of enacting either a medically needy or categorically needy program, Curtis v. Child, supra, 95 Idaho at 64-6, 501 P.2d at 1375—77 (1972). The amendments to I.C. § 56—209, enacted in 1973, have readopted a “categorically needy” program in Idaho and terminated the “medically needy” program. When the Haymans’ old age assistance grant was terminated June 30, 1976, because they no longer had a budget deficit they no longer qualified for medical assistance under I.C. § 56-209b.

In 1976 qualification for old age assistance was governed in part by two Department regulations.1 Regulation 3143 stated that in addition to other prerequisites one was required to have a “budget deficit,” that is, one’s income and resources could not exceed one’s allowable expenses. Regulation 3120 defined those allowable expenses which could be subtracted from income and resources in determining the presence of a budget deficit. Medical expenses were not included. Under this compilation the Haymans did not have a “budget deficit” (despite the fact that they did not have sufficient income and resources to pay their medical bills) and hence were eligible neither for old age assistance, nor, as a consequence, for medical assistance. The question before this court is whether the failure to include medical expenses in the determination of a budget deficit is arbitrary and capricious. I.C. § 67—5215(g)(6).

That the setting of specific requirements for participation in public assistance programs is largely a matter of State prerogative is established both by federal statute and case law. The very language of Title XIX of the social security act states that its purpose is to enable each State to provide medical assistance to its citizens, “as far as practicable under the conditions in such State . . . .” 42 U.S.C. § 1396 (1965), am. Dec. 31, 1973, Pub.L. 93-233, § 13(a)(1), 87 Stat. 960. The United States [713]*713Supreme Court has repeatedly upheld state welfare statutes under attack for failure to reach all conceivable persons in need, noting the “undisputed power” of the states, under the Social Security Act, to “set the level of benefits and the standard of need,” King v. Smith, 392 U.S. 309, 334, 88 S.Ct. 2128, 2142, 20 L.Ed.2d 1118, 1135 (1968), and that “the federal law gives each State great latitude in dispensing its available funds.” Dandridge v. Williams, 397 U.S. 471, 478, 90 S.Ct. 1153, 1158, 25 L.Ed.2d 491, 498 (1970).

This is so because under Title XIX federal funds are provided on a matching basis only, pegged to the level of State expenditure; and the expenditure of State funds is first and foremost a matter of State policy. It is a familiar “concern that the Federal Government not require a state legislature to appropriate more money for welfare purposes than it is willing and able to appropriate.” Dandridge, supra, 397 U.S. at 492, 90 S.Ct. at 1165, 25 L.Ed.2d at 506 (Douglas, J., dissenting).

In Dandridge, supra, the Maryland Aid to Families with Dependent Children program was challenged on constitutional and statutory grounds because it put an upper limit on the amount of aid which could be dispensed under the program per family. As a result families with a large number of children received less aid per child than those with fewer children. Upholding the program, the Court said:

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Related

Rhodes v. Industrial Commission
868 P.2d 467 (Idaho Supreme Court, 1993)
Posey v. State, Department of Health & Welfare
757 P.2d 712 (Idaho Court of Appeals, 1988)
Hayman v. State, Department of Health & Welfare
604 P.2d 724 (Idaho Supreme Court, 1979)

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Bluebook (online)
604 P.2d 724, 100 Idaho 710, 1979 Ida. LEXIS 512, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hayman-v-state-department-of-health-welfare-idaho-1979.