The New Jersey Superior Court, Appellate Division, upheld a decision denying an appellant’s application for benefits under New Jersey’s Aged, Blind, Disabled (ABD) Medicaid program because she had failed to apply for Social Security retirement benefits, despite her eligibility for them, without good cause. H.S. v. Ocean Cty. Bd. of Soc. Serv., No. A-0747-24, 2026 WL 453004 (N.J. Super Ct. App. Div. Feb. 18, 2026).
In February 2024, H.S. applied to Ocean County Board of Social Services (OCBSS) for benefits under New Jersey’s ABD Medicaid program. As a condition for eligibility for ABD Medicaid benefits under N.J. Admin. Code § 10:72-3.8, applicants are required to take all necessary steps to obtain all annuities, pensions, retirement, or disability benefits to which they are entitled unless they can show good cause for not doing so. In March 2024, OCBSS determined that H.S. was eligible for Social Security Retirement Income (SSRI) but had never applied for those benefits; as a result, it denied H.S.’s application.
H.S. requested a fair hearing. After considering documentary and testimonial evidence, the administrative law judge (ALJ) found that H.S. was eligible for SSRI but had elected to delay applying for it until she attained age 70 to obtain a higher monthly benefit. Because she had not obtained income to which she was entitled, Medicaid benefits were properly denied. The Division of Medical Assistance and Health Services (Division) adopted the ALJ’s decision, and H.S. appealed.
The New Jersey Superior Court, Appellate Division, reviewed the Division’s decision to determine whether it was arbitrary, capricious, or unreasonable. H.S. argued that the Division had improperly denied her application; she asserted that she had demonstrated good cause to delay obtaining SSRI because waiting two years would substantially increase her monthly benefit amount. She added that, even if she had not demonstrated good cause, she was still eligible for SSRI and thus had functionally fulfilled her obligations.
However, the Division stated that OCBSS generally understood good cause, although undefined in N.J. Admin. Code § 10:72-3.8, as circumstances beyond the applicant’s control—for example, administrative delays or incapacity—that prevent an applicant from obtaining benefits they are entitled to. The court found that the Division’s interpretation of good cause, which was consistent with other authorities and jurisdictions, was reasonable. Further, the court determined that H.S.’s choice to delay applying for SSRI was entirely within her control and amounted to a failure to meet the conditions required by New Jersey law to qualify for ABD Medicaid benefits.
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