Pfoser v. HarpsteadAnnotate this Case
The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court reversing a transfer penalty imposed by the Commissioner of the Minnesota Department of Human Services on David Pfoser, a disabled Medicaid recipient who resided in a long-term care facility, after he transferred partial proceeds from the sale of a house into a pooled special-needs trust, holding that Pfoser made a satisfactory showing that he intended to receive valuable consideration for his transfer of assets.
State and federal law impose a penalty on recipients, like Pfoser, of Medical Assistance for Long-Term Care benefits if they transfer assets for less than fair market value, but no penalty is imposed if the recipient makes a satisfactory showing that he intended to dispose of the assets either at fair market value or for other valuable consideration. See Minn. Stat. 256B.0595, subd. 4(a)(4). The Commissioner affirmed the transfer penalty imposed on Pfoser. The district court reversed, concluding that Pfoser received adequate compensation in the form of his vested equitable interest in the trust assets. The Supreme Court affirmed, holding that substantial evidence did not support the Commissioner's decision to uphold the penalty.