Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Public Benefits
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The Supreme Judicial Court held that the six-year statute of limitations for contract actions governed this case and that the efforts of Executive Office of Health and Human Services, Office of Medicaid (MassHealth) to collect overpayments made to providers in the State Medicaid program were time barred.In 2005, MassHealth sent an audit notice to a provider, Suburban Home Health Care, Inc., but took no further action until 2016, when it initiated recovery proceedings. Suburban sought declaratory relief, arguing that the proceedings were barred under the statute of limitations for "actions of contract" in Mass. Gen. Laws ch. 260, 2. The superior court denied relief, concluding that the administrative proceedings to collect the overpayments could not be considered civil actions, and therefore, no statute of limitations applied. The Supreme Judicial Court reversed, holding that the six-year statute of limitations for contract actions applied and that MassHealth's action was time barred. View "Suburban Home Health Care, Inc. v. Executive Office of Health and Human Services, Office of Medicaid" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the superior court reversing the determination of the Massachusetts Office of Medicaid's board of hearings that Plaintiff's home was a countable asset, making her ineligible for Medicaid long-term care benefits, holding that the superior court did not err.While they were both still living, Plaintiff and her husband created an irrevocable trust, the corpus of which included their home. The terms of the trust granted Plaintiff, during her lifetime, a limited power of appointment to appoint all or any portion of the trust principal to a nonprofit or charitable organization over which she had no controlling interest. MassHealth denied Plaintiff's application for long-term care benefits, determining that the home was a countable asset because Plaintiff purportedly could use her limited power of appointment to appoint portions of the home's equity, which was included as part of the trust principal, to the nursing home where Plaintiff lived as payment for her care. The superior court reversed. The Supreme Judicial Court reversed, holding that the plain terms of the trust neither intended for nor permitted Plaintiff to exercise her limited power of appointment for her benefit, as contemplated by MassHealth. View "Fournier v. Secretary of Executive Office of Health & Human Services" on Justia Law

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The Supreme Judicial Court reversed the judgment of the superior court judge affirming the decision of a hearing officer upholding MassHealth's denial of Plaintiff's application for Medicaid benefits on the grounds that Plaintiff's life estate interest in certain property as a beneficiary rendered Plaintiff ineligible for long-term care benefits, holding that Plaintiff's life estate was not a countable asset for Medicaid eligibility purposes.Plaintiff created a trust and transferred her home to the trust. Plaintiff had a life estate interest in the property under the trust, and the other five beneficiaries - her children - had a remainder interest as joint tenants with rights of survivorship. After Plaintiff moved to a long-term nursing facility she applied for long-term benefits from MassHealth. MassHealth denied the application, determining that Plaintiff's countable assets exceeded the $2,000 limit. A hearing officer and a superior court judge affirmed. The Supreme Court reversed, holding (1) because the trust was a nominee trust and not a true trust, Plaintiff's only interest in the property was a life estate; and (2) it was error to include the value of the property as an asset in Plaintiff's Medicaid eligibility determination. View "Guilfoil v. Secretary of Executive Office of Health & Human Services" on Justia Law

Posted in: Public Benefits
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On appeal from a federal appellate court's decision that the Federal Medicare scheme prohibits State Medicaid agencies, including MassHealth, from receiving funds from Medicare, the Supreme Judicial Court ordered that this case be remanded for modification of the declaratory judgment, holding that MassHealth demonstrated a sufficient change in circumstances to warrant modification to allow MassHealth to seek reimbursement where the liable third party is Medicare.In Atlanticare Medical Center v. Commissioner of the Division of Medical Assistance, 439 Mass. 1, 3, 5 (2003) (Altanticare I), the Supreme Judicial Court concluded that the Federal Medicaid scheme tasked the State Medicaid agency, not individual providers, with seeking reimbursement from liable third-party insurers, including Medicare. When the Center for Medicare & Medicaid Services (CMS) refused to issue reimbursements from Medicare to MassHealth, MassHealth brought suit. In 2011, the United States Court of Appeals for the First Circuit held that the Federal Medicare scheme prohibited MassHealth from receiving funds from Medicare. Therefore, a Federal Medicare regulation was amended to acknowledge the practice of State Medicaid agencies obtaining Medicare reimbursements through providers, rather than seeking such reimbursements directly from Medicare. MassHealth sought to modify the declaratory judgment and restore its ability to obtain reimbursements from providers, rather than liable third parties. The Supreme Judicial Court remanded the case for modification of the judgment, holding that changed circumstances required modification. View "Atlanticare Medical Center v. Division of Medical Assistance" on Justia Law

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Neither the grant in an irrevocable trust of a right of occupancy and use in a primary residence to an applicant nor the retention of a life estate by the applicant in the applicant’s primary residence makes the equity in the home owned by the trust a countable asset for the purpose of determining Medicaid eligibility for long-term care benefits under the Federal Medicaid Act.At issue before the Supreme Judicial Court in these two cases was whether applicants were eligible for long-term care benefits under the Act Act where they created an irrevocable trust and deeded their home - their primary asset - to the trust but retained the right to use and reside in the home for the rest of their life. The Director of the Massachusetts Office of Medicaid (MassHealth) found that the applicants were not eligible for long-term care benefits. The superior court upheld MassHealth’s determinations. The Supreme Judicial Court reversed the judgments in both cases because MassHealth found that the equity in both homes was a “countable” asset whose value exceeded the asset eligibility limitation under the Act. View "Daley v. Secretary of Executive Office of Health & Human Services" on Justia Law

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After Defendants were charged with Medicaid fraud, the Commonwealth obtained search warrants to obtain and search designated e-mail accounts of Defendants' former billing director. Defendants moved for a protective order, claiming that the attorney-client privilege protected many of the e-mails. A motion judge amended the order to permit the Commonwealth to search the e-mails by using a "taint team," assistant attorneys general not involved in the investigation or prosecution of Defendants. Defendants filed a petition seeking relief from the order. The Supreme Court answered reported questions from the county court by holding (1) the Commonwealth may, by means of an ex parte search warrant, search the post-indictment emails of a criminal defendant; and (2) the "taint team" procedure was permissible under the Massachusetts Constitution. View "Preventive Med. Assocs. v. Commonwealth" on Justia Law

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This case involved Commonwealth Care, a state-initiated program that provided structured premium assistance for low-income Massachusetts residents. In 2009, the Legislature made certain changes to the eligibility requirements of Commonwealth Care, enacted in a two-part supplemental appropriation for fiscal year 2010. Section 31(a) of the appropriation excluded all aliens who were federally ineligible under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), 8 U.S.C. 1601-1646, from participation in Commonwealth Care. Plaintiffs were individuals who either have been terminated from Commonwealth Care or have been denied eligibility solely as a result of their alienage. The court held that section 31(a) could not pass strict scrutiny and that the discrimination against legal immigrants that its limiting language embodied violated their rights to equal protection under the Massachusetts Constitution. View "Finch & others v. Commonwealth Health Ins. Connector Auth. & others" on Justia Law

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This action arose when claimant, a former customer service representative for Verizon New England, Inc. ("Verizon"), was denied unemployment benefits. At issue was whether the board of review of the division of unemployed assistance ("board") erred because Verizon took the "last step" in the termination process that entitled claimant to unemployment benefits. The court affirmed the judgment of the district court, which affirmed the decision of the board, to deny claimant benefits because the court agreed with the board's conclusion that the claimant did not meet her burden of showing that her decision to leave was involuntary, where she was not compelled to apply for the termination, did not believe her job was in jeopardy, and left in part for personal reasons.