Randy L. Hotmer v. Indiana Family and Social Services Administration

CourtIndiana Court of Appeals
DecidedJune 30, 2020
Docket19A-PL-2694
StatusPublished

This text of Randy L. Hotmer v. Indiana Family and Social Services Administration (Randy L. Hotmer v. Indiana Family and Social Services Administration) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Randy L. Hotmer v. Indiana Family and Social Services Administration, (Ind. Ct. App. 2020).

Opinion

FILED Jun 30 2020, 7:30 am

CLERK Indiana Supreme Court Court of Appeals and Tax Court

ATTORNEY FOR APPELLANT ATTORNEYS FOR APPELLEE Ralph C. Melbourne Curtis T. Hill, Jr. Church Langdon Lopp & Banet, LLC Attorney General New Albany, Indiana Benjamin M. L. Jones Deputy Attorney General Indianapolis, Indiana

IN THE COURT OF APPEALS OF INDIANA

Randy L. Hotmer, June 30, 2020 Appellant-Petitioner, Court of Appeals Case No. 19A-PL-2694 v. Appeal from the Clark Circuit Court Indiana Family and Social The Honorable William A. Services Administration, Dawkins, Magistrate Appellee-Respondent Trial Court Cause No. 10C02-1807-PL-82

Crone, Judge.

Case Summary [1] Randy L. Hotmer purchased two irrevocable annuities; pursuant to the

annuities’ contract documents, the monthly payments were made to his wife.

Hotmer, who was in a nursing home, applied for Medicaid benefits with the

Court of Appeals of Indiana | Opinion 19A-PL-2694 | June 30, 2020 Page 1 of 8 Indiana Family and Social Services Administration (FSSA). FSSA ruled that

because Hotmer was the owner of the annuities, the income from the annuities

must be attributed to him, and because that income resulted in Hotmer

exceeding the income limit for Medicaid eligibility, FSSA denied his

application. Hotmer petitioned for judicial review of FSSA’s ruling, and the

trial court affirmed. Hotmer now appeals, arguing that FSSA erred in

attributing the annuity income to him and in denying his application. We agree

and therefore reverse and remand for further proceedings.

Facts and Procedural History [2] The relevant facts are undisputed. Hotmer was born in 1948. In April 2017, he

entered a nursing home for long-term care. Over the next few months, he filled

out applications for and ultimately purchased two eight-year annuities, one

from Elco Mutual and one from NGL. On the applications, Hotmer directed

that the monthly checks be made out to his wife as payee, and he also named

her as the primary beneficiary who would be entitled to receive any remaining

payments after his death. The annuity contract documents list Hotmer as the

annuitant, or the owner, of the annuities, and state that the applications are part

of the contracts. The Elco Mutual contract states, “Annuity payments will be

made to the Owner, or as otherwise directed by the Owner, beginning on the

Annuity Date.” Appellant’s App. Vol. 3 at 40. The contract further states,

“This contract is irrevocable. It may not be transferred, assigned, surrendered

or commuted during Your lifetime.… Neither the Annuitant nor the

Beneficiary may be changed.” Id. at 41. The NGL contract states, “[NGL] will

Court of Appeals of Indiana | Opinion 19A-PL-2694 | June 30, 2020 Page 2 of 8 make annuity payments to the Annuitant commencing on the Annuity Date.”

Id. at 45. The contract further states, “This Contract is irrevocable. It may not

be altered, transferred, assigned, surrendered or commuted during Your

lifetime.… Neither the Annuitant nor any Beneficiary may be changed.” Id. at

47.

[3] In October 2017, Hotmer applied for Medicaid benefits with FSSA, which

administers the Medicaid program in Indiana. The local FSSA office

determined that the annuity payments belonged to Hotmer as the owner of the

annuity, and it denied his application on the basis that those payments boosted

his monthly income above the applicable eligibility limit. 1 Hotmer petitioned

for administrative review of that decision. An administrative law judge (ALJ)

overturned the denial based on 42 U.S.C. § 1396r-5(b)(2)(A)(i) (Section 1396r-

5), which states,

in the case of income not from a trust, unless the instrument providing the income otherwise specifically provides[,] if payment of income is made solely in the name of the institutionalized spouse [Hotmer] or the community spouse [his wife], the income shall be considered available only to that respective spouse[.]

1 Absent the annuity payments, Hotmer’s monthly income is approximately $200 below the limit. Each of the annuity payments exceeds $200.

Court of Appeals of Indiana | Opinion 19A-PL-2694 | June 30, 2020 Page 3 of 8 The ALJ concluded that because the annuity payments were made solely in the

name of Hotmer’s wife, they were considered available only to his wife, and

therefore Hotmer’s income did not exceed the limit.

[4] FSSA petitioned for review of the ALJ’s decision. FSSA’s ultimate authority

remanded to the ALJ with instructions to examine the evidence and Section

1396r-5 in their entirety, further address the issue of income, and provide

findings and conclusions to support her decision. On remand, the ALJ found

that Hotmer’s annuities,

of which he is the owner/annuitant, is [sic] being paid directly to [his wife] for her benefit only. [Hotmer] does not have access to the monthly income. [His wife] is the recipient of the monthly payments which are deposited into her account for her use only. Therefore the annuity income is not countable under [Hotmer’s] countable monthly income.

Appellant’s App. Vol. 2 at 49.

[5] FSSA again petitioned for review, and FSSA’s ultimate authority issued a

decision that reads in relevant part,

After review of the evidence, it is clear that [Hotmer] is the owner of the annuities and as owner the income source must be attributed to him regardless of who he has assigned as a payee. [Hotmer’s] income must be used for his care since he applied for Medicaid. 42 CFR 435.608 states, “(a) As a condition of eligibility, the agency must require applicants and beneficiaries to take all necessary steps to obtain any annuities, pensions, retirement, and disability benefits to which they are entitled, unless they can show good cause for not doing so.” The State’s

Court of Appeals of Indiana | Opinion 19A-PL-2694 | June 30, 2020 Page 4 of 8 original decision to deny Medical Assistance to the Aged to [Hotmer] for the application dated October 20, 2017 is sustained.

Id. at 21. Hotmer petitioned for judicial review of the decision pursuant to the

Indiana Administrative Orders and Procedures Act (the Act). After a hearing,

the trial court affirmed FSSA’s decision. Hotmer now appeals.

Discussion and Decision [6] In an appeal involving an administrative agency’s decision, our standard of

review is governed by the Act, and we are bound by the same standard of

review as the trial court. Walker v. State Bd. of Dentistry, 5 N.E.3d 445, 448 (Ind.

Ct. App. 2014), trans. denied. “We do not try the case de novo and do not

substitute our judgment for that of the agency.” Id.

We will reverse the administrative decision only if it is: (1) arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law; (2) contrary to a constitutional right, power, privilege, or immunity; (3) in excess of statutory jurisdiction, authority, or limitations, or short of statutory right; (4) without observance of procedure required by law; or (5) unsupported by substantial evidence.

Id. (citing Ind. Code § 4-21.5-5-14). “A decision is arbitrary and capricious

when it is made without consideration of the facts and lacks any basis that may

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Related

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5 N.E.3d 445 (Indiana Court of Appeals, 2014)
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836 N.E.2d 311 (Indiana Court of Appeals, 2005)

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