State Can Recoup Medicaid Benefits From Estate Even If Recipient Wasn’t Qualified to Receive Them

A Minnesota appeals court holds that the state can recoup Medicaid benefits from the estate of a Medicaid recipient who received benefits through a Medicaid waiver program even if he wasn’t actually qualified for the waiver program. In re the Estate of: Raymond Deforest Trahan (Minn. Ct. App., No. A19-1020, Feb. 3, 2020).

Raymond Trahan received Medicaid benefits through a waiver program that provides health services to individuals who need nursing home level care, but who want to remain in the community. After Mr. Trahan died, the state filed a claim against his estate to recover benefits paid on his behalf.

The estate disallowed the claim and then filed a petition in court, listing services provided to Mr. Trahan worth $158,384.35. The trial court denied the petition, ruling that Mr. Trahan was not eligible for the waiver program because he did not need nursing home level care, so the state wrongly provided benefits and could not recoup them. The state appealed.

The Minnesota Court of Appeals reverses, holding that the state can recoup benefits. The court rules that the trial court should not have made a determination about whether Mr. Trahan was qualified for the waiver program. According to the court, Mr. Trahan “accepted and received benefits through the [waiver] program, and recovery of the costs of such benefits from the estate is explicitly authorized by law.” One judge dissents, arguing that the evidence shows the benefits were not correctly paid, so they cannot be recovered.

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