Marie Synesael v. David Ling

691 F.2d 1213, 1982 U.S. App. LEXIS 24685
CourtCourt of Appeals for the Seventh Circuit
DecidedOctober 20, 1982
Docket82-1038
StatusPublished
Cited by7 cases

This text of 691 F.2d 1213 (Marie Synesael v. David Ling) is published on Counsel Stack Legal Research, covering Court of Appeals for the Seventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Marie Synesael v. David Ling, 691 F.2d 1213, 1982 U.S. App. LEXIS 24685 (7th Cir. 1982).

Opinions

POSNER, Circuit Judge.

This appeal is from an order upholding the validity of an Indiana regulation limiting the Medicaid benefits that may be received by individuals who transfer assets in order to establish eligibility for Medicaid. The regulation provides that if a transfer for inadequate consideration was made not more than five years before the application was made, and the “uncompensated value” of the assets transferred, which is to say the difference between what they were worth and what the transferor actually received, exceeded $12,000, the transfer will be presumed to have been made for the purpose of establishing eligibility. Unless this presumption is rebutted, the applicant is ineligible to receive Medicaid benefits until he has incurred medical expenses equal to the uncompensated value of the transfer. But the period of ineligibility has a cap: two years if the uncompensated value does not exceed $12,000, five years if it does.

The regulation thus has two parts: a five-year “reach-back” provision, and a formula for determining the period of ineligibility if an improper transfer is found. Both parts are challenged in this appeal as contrary to the Boren-Long amendment, which is section 5(a) and (b) of Pub.L. 96— 611, 94 Stat. 3567 (Dec. 28, 1980).

Section 5(b) adds to 42 U.S.C. § 1396a a new subsection, (j)(l), which provides that “notwithstanding any other provision of this subchapter” a state may deny Medicaid to an otherwise eligible applicant who would not have been eligible had he not transferred assets for less than their fair market value. However, if the state wants to take up this option it must “specify a procedure . . . which ... is not more restrictive than the procedure specified in” 42 U.S.C. § 1382b(c), added by section 5(a), which requires that in determining eligibility for assistance under certain other federal welfare programs assets transferred at less than fair market value within the preceding two years must be counted among the applicant’s assets. The Indiana regulation requiring that some assets transferred at less than market value be counted even if they were transferred more than two years before the application for Medicaid was made seems inconsistent with the terms of section 1382b(c); but before concluding that it is we must consider the special status of Indiana under the Medicaid program.

When Congress expanded Medicaid eligibility in 1972, it gave the states an option to limit Medicaid assistance to people who would have been eligible under the state’s plan that was in effect on January 1 of that year. See 42 U.S.C. § 1396a(f); 42 C.F.R. § 435.121. States that have taken up this option, and Indiana is one of them, are known as “section 209(b)” states. Those that do not, that offer broader coverage, are known as “SSI” states. See Schweiker v. Gray Panthers, 453 U.S. 34, 38-39, 101 S.Ct. 2633, 2637-2638, 69 L.Ed.2d 460 (1981). The parties agree that under the Indiana Medicaid plan in force on January 1, 1972, [1215]*1215applicants who had transferred assets at any time within the preceding five years either for the purpose or with the effect of establishing eligibility for Medicaid were ineligible by virtue of Ind.Code §§ 12-1-5-1(f), 12-1-7-14.9. We therefore have to decide whether the Boren-Long amendment was intended to broaden Medicaid eligibility in 209(b) states. If so, Indiana’s five-year reach-back provision presumably would be invalid on the authority of such cases as Beltran v. Myers, 677 F.2d 1317, 1320-21 (9th Cir. 1982), dealing with similar provisions in SSI states. But if Congress’s intent was only to allow states to disqualify applicants who previously had been eligible even though they had transferred assets for less than fair market value, then Indiana’s special status as a 209(b) state, coupled with the fact that its five-year reach-back provision dates back to January 1, 1972, would make the Indiana regulation valid.

We find — in agreement with the only decision we have found that deals with the question, Randall v. Lukhard, 536 F.Supp. 723, 732-33 (W.D.Va.1982) — no indication in the language or history of the amendment that Congress wanted to broaden Medicaid eligibility in section 209(b) states. It is true that 42 U.S.C. § 1396a(j)(l) is introduced by the words “notwithstanding any other provision of this subchapter,” and the subchapter includes section 1396a(f), which created the section 209(b) exemption. But the quoted words do not introduce the “not more restrictive” provision in section 1396a(j)(l), which is in the second sentence of the section; they introduce the first sentence, the remainder of which reads, “an individual who would otherwise be eligible for medical assistance under the State plan approved under this subchapter may be denied such assistance if such individual would not be eligible for such medical assistance but for the fact that he disposed of resources for less than fair market value.” In context the introductory words just mean that notwithstanding any statutory provision that might appear to entitle an applicant to Medicaid benefits, he may be denied them if he transferred assets at less than their fair market value. In other words, the premise for applying section 1396a(j)(l), with its restriction on implementing procedures, is that some other provision in the Medicaid statute would, but for that section, entitle the applicant to benefits. If he is not entitled to benefits under any other provision because he lives in a section 209(b) state in which he would not have been eligible for benefits under the state plan in force on January 1, 1972, section 1396a(j)(l) does not come into play at all, and it therefore does not invalidate Indiana’s reach-back provision.

This interpretation of section 1396a(j)(l) is consistent with the purpose of the BorenLong amendment, which was, in the words of Senator Long, “to grant the States more flexibility.” 126 Cong.Rec. S16505 (1980). He also said that “generally, State rules could not be more restrictive than the Federal SSI rule,” id. at S16506, but in context this is a reference to the fact that the amendment empowers the states to tighten up their existing eligibility standards. Senator Long did not want to give states carte blanche to disqualify, because of transfers of assets below fair market value, people previously eligible for Medicaid benefits; but this does not mean that he wanted to enlarge the Medicaid rolls in 209(b) states.

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691 F.2d 1213, 1982 U.S. App. LEXIS 24685, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marie-synesael-v-david-ling-ca7-1982.