Randall v. Lukhard

536 F. Supp. 723, 1982 U.S. Dist. LEXIS 9529
CourtDistrict Court, W.D. Virginia
DecidedApril 16, 1982
DocketCiv. A. 80-0050-C
StatusPublished
Cited by9 cases

This text of 536 F. Supp. 723 (Randall v. Lukhard) is published on Counsel Stack Legal Research, covering District Court, W.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Randall v. Lukhard, 536 F. Supp. 723, 1982 U.S. Dist. LEXIS 9529 (W.D. Va. 1982).

Opinion

OPINION and ORDER

TURK, Chief Judge.

In an effort to prevent fraud in the use of Medicaid funds, the Commonwealth of Virginia has employed a transfer of assets rule which disqualifies those Medicaid applicants or recipients who have transferred property to other persons for a consideration which is less than the fair market value of the property. Plaintiffs filed this class action challenging the Commonwealth’s transfer of assets rule on the grounds that the transfer rule, as it has existed in all of its forms since 1965, violated Title XIX of the Social Security Act, as amended, and also the due process and equal protection clauses of the fourteenth amendment. This court possesses jurisdiction of these matters pursuant to 28 U.S.C. § 1331 and 28 U.S.C. § 1343(3).

Congress established the Medicaid program in 1965 as Title XIX of the Social Security Act, 42 U.S.C. § 1396 et seq. If a state chooses to participate in the program, *726 the federal government will reimburse the state for a portion of the costs of medical treatment for needy persons. A participating state must develop a plan containing “reasonable standards ... for determining eligibility for and the extent of medical assistance.” 42 U.S.C. § 1396a(a)(17). The plan must comply with the requirements imposed both by the Social Security Act and by the Secretary of Health and Human Services. Id., Schweiker v. Gray Panthers, 453 U.S. 34, 101 S.Ct. 2633, 2636, 69 L.Ed.2d 460 (1981).

When first enacted in 1965, Medicaid required participating states to provide medical assistance to “categorically needy” individuals. The “categorically needy” were persons eligible to receive cash payments under one of four welfare programs established elsewhere in the Act. 42 U.S.C. § 1396a(a)(10) (1970 ed.). A participating state also had the option, however, of providing medical assistance to the “medically needy,” those persons who possessed incomes or resources too large to qualify for categorical welfare assistance, but too small to pay for their medical expenses. In assessing whether an individual qualified for medical assistance as either a “categorically needy” or “medically needy” person, a state was required to evaluate financial need using only “such income and resources as áre, as determined in accordance with standards prescribed by the Secretary, available to the applicant or recipient.” 42 U.S.C. § 1396a(a)(17)(B).

As of January 1, 1972, the standards promulgated by the Secretary to define the term “available” stated, in pertinent part, (a) State Plan requirements: A State plan under title XIX of the Social Security Act must:

(2) With respect to both the categorically needy and, if they are included in the plan, the medically needy:
(1) Provide that only such income and resources as are actually available will be considered and that income and resources will be reasonably evaluated....

45 C.F.R. § 248.21(a)(2)(i) [1972] (later recodified at 42 C.F.R. § 448.3(b)(1)) (emphasis supplied).

Virginia chose to participate in the Medicaid program and, as of January 1, 1972, Virginia’s program applied a transfer of assets rule to all applicants who sought medical assistance under the Old Age Assistance and Aid to the Permanently and Totally Disabled programs. In general the rule required an applicant who had transferred real or personal property within one or two years of the date of his application, for a consideration less than the fair market value of the property, to demonstrate that the transfer was not for the purpose of becoming eligible for Medicaid. 1

In 1972 Congress revised the Social Security Act. The welfare programs aiding the aged, blind, and disabled (but not dependent children) were repealed, effective January 1, 1974. A new program, Supplemental Security Income for the Aged, Blind, and Disabled (SSI), gave the federal *727 government the responsibility not only for partially funding payments but also for setting eligibility standards. 42 U.S.C. § 1381 et seq., Pub.L. 92-603, 86 Stat. 1465 (1972). The SSI standards of need were more liberal than those used by some states under the previous state-run categorical need programs, and thus SSI confronted these states with the possibility of providing Medicaid assistance to a much larger number of persons.

“[I]n order not to impose a substantial fiscal burden on these States” or discourage them from participating in Medicaid, Congress created the “§ 209(b) option”, S.Rep. No.553, 93d Cong., 1st Sess., 56 (1973). By exercising this option a state could ignore the more liberal SSI Medicaid eligibility standards and provide Medicaid assistance only to those persons who would have been eligible for the state Medicaid plan in effect on January 1, 1972. 42 U.S.C. § 1396a. Virginia chose to exercise the § 209(b) option. Therefore the Commonwealth continued to apply a transfer of assets rule to aged, blind, and disabled applicants for Medicaid, as it had done on January 1,1972.

Plaintiffs filed this class action on April 24,1980, seeking declaratory and injunctive relief on the grounds that Virginia’s transfer of assets rule violated Title XIX of the Social Security Act and the due process and equal protection clauses of the fourteenth amendment. Subsequently, on December 28, 1980, President Carter signed Amendment No. 1936 to the Pneumococcal Vaccine Act, H.R. 8406, Section 5 of Public Law 96-611 (the Boren-Long Amendment). Despite its title, the Amendment in part permitted all state Medicaid plans to employ a transfer of assets rule which presumed that a transfer of property for less than fair market value within the previous 24 months was for the purpose of becoming eligible for Medicaid. 2 To rebut the presumption an applicant must offer “convincing evidence” *728 that the transfer was made exclusively for some other purpose. Id.; codified at 42 U.S.C. § 1382b(c)(2).

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Related

Randall v. Lukhard
637 F. Supp. 167 (W.D. Virginia, 1986)
Dineen v. Missouri State Division of Family Services
697 S.W.2d 564 (Missouri Court of Appeals, 1985)
Reed v. Lukhard
591 F. Supp. 1247 (W.D. Virginia, 1984)
Randall v. Lukhard
729 F.2d 966 (Fourth Circuit, 1984)
Randall ex rel. Liskey v. Lukhard
709 F.2d 257 (Fourth Circuit, 1983)
Marie Synesael v. David Ling
691 F.2d 1213 (Seventh Circuit, 1982)

Cite This Page — Counsel Stack

Bluebook (online)
536 F. Supp. 723, 1982 U.S. Dist. LEXIS 9529, Counsel Stack Legal Research, https://law.counselstack.com/opinion/randall-v-lukhard-vawd-1982.