Maine Pooled Disability Trust v. Hamilton, No. 18-1223 (1st Cir. 2019)Annotate this Case
The First Circuit affirmed the judgment of the district court concluding that transfers of assets by individuals age sixty-five or older into "pooled special needs trusts" are among those transfers that the Medicaid statute counts against eligibility for long-term care benefits, holding that when a beneficiary who is age sixty-five years or older gives up her assets for less than fair market value to a pooled special needs trust, there has been a transfer that triggers a temporary period of ineligibility.
Following Yvonne Richardson's deposit of funds into her Maine Pooled Disability Trust (MPDT) account, the Maine Department of Health and Human Services (MDHHS) issued a notice threatening to suspend Medicaid coverage. Richardson and MPDT filed this lawsuit seeking a declaration that her transfer of assets into a pooled special needs trust was not a transfer that affected Medicaid eligibility. The district court dismissed the complaint, concluding that MDHHS correctly applied the governing statute in reaching its conclusion. The First Circuit affirmed, holding that the district court's judgment granting MDHHS's motion to dismiss rested on a reasonable interpretation of the statute.