Hill v. The Div. of Soc. Servs.

CourtCourt of Appeals of North Carolina
DecidedJanuary 16, 2024
Docket23-197
StatusPublished

This text of Hill v. The Div. of Soc. Servs. (Hill v. The Div. of Soc. Servs.) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hill v. The Div. of Soc. Servs., (N.C. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA23-197

Filed 16 January 2024

Rutherford County, No. 22 CVS 38

JEAN HILL and JAMES HILL, Petitioners,

v.

THE DIVISION OF SOCIAL SERVICES AND THE DIVISION OF HEALTH BENEFITS OF THE NORTH CAROLINA DEPARTMENT OF HEALTH AND HUMAN SERVICES, Respondents.

Appeal by petitioners from order entered 7 October 2022 by Judge J. Thomas

Davis in Rutherford County Superior Court. Heard in the Court of Appeals 3 October

2023.

Ott Cone & Redpath, P.A., by Stephen J. White, for petitioners-appellants.

Attorney General Joshua H. Stein, by Assistant Attorney General Chris D. Agosto Carreiro and Assistant Attorney General Adrian W. Dellinger, for the State.

ZACHARY, Judge.

This case concerns a single issue of law: whether great-aunts and great-uncles

were included within the definition of “caretaker relatives” under the North Carolina

State Medicaid Plan prior to 1 May 2022. Petitioners Jean and James Hill (“the Hills”)

appeal from the superior court’s order affirming the ruling by Respondent North

Carolina Department of Health and Human Services (“DHHS”), which approved the

Hills for Family Planning Medicaid benefits rather than retroactive and ongoing full HILL V. THE DIV. OF SOC. SERVS.

Opinion of the Court

Medicaid benefits covering the medical expenses that they incurred during their

period of caring for their great-niece. After careful review, we affirm.

I. Background

At the outset, the Hills acknowledge that “[t]his appeal does not raise any

substantive disputes concerning the material facts.” We therefore need only recite the

legal and procedural facts pertinent to our analysis.

A. Medicaid

“The Medicaid program was established by Congress in 1965 to provide federal

assistance to states which chose to pay for some of the medical costs for the needy.”

Correll v. Div. of Soc. Servs., 332 N.C. 141, 143, 418 S.E.2d 232, 234 (1992). “Whether

a state participates in the program is entirely optional. However, once an election is

made to participate, the state must comply with the requirements of federal law.” Id.

(cleaned up). In essence, “Medicaid offers the States a bargain: Congress provides

federal funds in exchange for the States’ agreement to spend them in accordance with

congressionally imposed conditions.” Armstrong v. Exceptional Child Ctr., Inc., 575

U.S. 320, 323, 191 L. Ed. 2d 471, 476 (2015).

“The federal and state governments share the cost of Medicaid, but each state

government administers its own Medicaid plan. State Medicaid plans must, however,

comply with applicable federal law and regulations.” N.C. Dep’t of Health & Hum.

Servs. v. Parker Home Care, LLC, 246 N.C. App. 551, 556, 784 S.E.2d 552, 556, disc.

review denied, 369 N.C. 183, 793 S.E.2d 690 (2016) (citation omitted); see also 42

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U.S.C. § 1396c. “Within broad Federal rules, each State decides eligible groups, types

and range of services, payment levels for services, and administrative and operating

procedures.” 42 C.F.R. § 430.0 (2022). A “State plan” is “a comprehensive written

commitment by a Medicaid agency, submitted under [42 U.S.C. § 1396a], to

administer or supervise the administration of a Medicaid program in accordance with

Federal requirements.” Id. § 400.203.

“North Carolina’s Medicaid plan describes the nature and scope of its Medicaid

program and gives assurance that it will be administered in conformity with specific

federal statutory requirements and other applicable official issuances of the federal

Department of Health and Human Services.” Martin v. N.C. Dep’t of Health & Hum.

Servs., 194 N.C. App. 716, 720, 670 S.E.2d 629, 633 (2009). State Medicaid Plans and

State Plan Amendments approved by the Centers for Medicare and Medicaid Services

(“CMS”) “have the force and effect of rules adopted pursuant to Article 2A of Chapter

150B of the General Statutes.” N.C. Gen. Stat. § 108A-54.1B(d) (2021).

B. “Caretaker Relative” Status

CMS has promulgated a regulation defining “caretaker relative,” a category of

individuals who may be eligible for full Medicaid benefits, which includes an optional

expansion of the category that a state may choose:

Caretaker relative means a relative of a dependent child by blood, adoption, or marriage with whom the child is living, who assumes primary responsibility for the child’s care (as may, but is not required to, be indicated by claiming the child as a tax dependent for Federal income tax purposes),

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and who is one of the following—

(1) The child’s father, mother, grandfather, grandmother, brother, sister, stepfather, stepmother, stepbrother, stepsister, uncle, aunt, first cousin, nephew, or niece.

(2) The spouse of such parent or relative, even after the marriage is terminated by death or divorce.

(3) At State option, another relative of the child based on blood (including those of half-blood), adoption, or marriage; the domestic partner of the parent or other caretaker relative; or an adult with whom the child is living and who assumes primary responsibility for the dependent child’s care.

42 C.F.R. § 435.4 (second emphasis added).

Prior to the enactment of the Patient Protection and Affordable Care Act (“the

Affordable Care Act”),1 North Carolina recognized a more expanded definition of

“caretaker relative.” The North Carolina Administrative Code contained a regulation

(“the Rule”)2 that reflected this expanded definition:

“Caretaker Relative” means a parent or a person in one of the following groups with whom a child lives:

(a) any blood relative, including those of half-blood, and including first cousins, nephews, or nieces, and persons of preceding generations as denoted by prefixes of grand, great, or great-great;

1 The Affordable Care Act is the comprehensive federal health care reform legislation enacted

in 2010 with the primary goals of “increas[ing] the number of Americans covered by health insurance and decreas[ing] the cost of health care.” Nat’l Fed’n of Indep. Bus. v. Sebelius, 567 U.S. 519, 538, 183 L. Ed. 2d 450, 467 (2012). 2 DHHS repealed the Rule with an effective date of 1 May 2022. 36 N.C. Reg. 1869–72 (June

1, 2022). It is undisputed, however, that at all times relevant to this appeal, this explicit repeal had not yet taken effect.

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(b) stepfather, stepmother, stepbrother, and stepsister;

(c) persons who legally adopt a child, their parents as well as the natural and other legally adopted children of such persons, and other relatives of the adoptive parents in accordance with state law;

(d) spouses of any persons named in the groups in Sub- item (19)(a)–(c) of this Rule even after the marriage is terminated by death or divorce.

10A N.C. Admin.

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