Guilfoil v. Secretary of Executive Office of Health & Human ServicesAnnotate this Case
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.