Federal Court Upholds N.C.'s Medicaid Lien Statute

A federal district court in North Carolina holds that the state's Medicaid reimbursement statutes comply with Ahlborn and therefore a Medicaid recipient's claim that the state is not entitled to recover its Medicaid lien lacks merit. Armstrong v. Cansler (U.S. Dist. Ct., W.D.N.C., No. 5:07-CV-37-RLV, June 28, 2010).

Through her guardians, Emily Armstrong sued a health care provider for personal injuries she had sustained. The matter settled, but not before Emily had received medical assistance benefits from the state's Medicaid agency. The settlement did not specifically allocate an amount to medical expenses.

When the state sought reimbursement of the medical expenses it had paid on Emily's behalf from the settlement proceeds, Emily's guardians sought a determination that the state was not entitled to any of the recovered funds. They asserted that the state's Medicaid assignment and subrogation statutes, which limit the state's reimbursement for medical expenses to one-third of the settlement, violate the U.S. Supreme Court's decision in Ahlborn v. Arkansas Dept. of Human Services. They also argued that the North Carolina Supreme Court had erred in Andrews v. Haygood, a case with similar facts, in holding that the state's statutory scheme complied with Ahlborn. The state countered that Andrews was dispositive, required the state to be reimbursed, and complied with Ahlborn. Both parties filed motions for summary judgment.

The U.S. District Court for the Western District of North Carolina grants the state's motion for summary judgment, concluding that the North Carolina Supreme Court correctly determined that the North Carolina reimbursement statutes are consistent with federal Medicaid law as construed by Ahlborn.

For the full text of this decision, go to: https://attorney.elderlawanswers.com/full-text-of-opinion-in-armstrong-v-cansler--us-distr-ct-wdnc-no-507-cv-37-rlv-june-28-2010-8432

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