An Ohio appeals court rules that the state's claim for Medicaid reimbursement from a decedent's estate is barred by a statute of limitations that imposes a maximum period of one year from the decedent's death to file a claim. In re Estate of Centorbi (Ohio Ct. App., No. 93501, Feb. 11, 2010).
Josephine Centorbi, a Medicaid recipient, died intestate on February 12, 2007, and her estate was closed without administration on December 21, 2007. On December 11, 2008, the state of Ohio sought to vacate the final accounting and to reopen the estate so that it could file a claim for reimbursement of Medicaid expenses paid on Ms. Centorbi's behalf. The trial court concluded the state's request was barred by a one-year statute of limitations and dismissed the action.
The state appealed, asserting that because the administrator had failed to complete a Medicaid estate recovery form, the statute of limitations had not been triggered. Moreover, the state argued, statutes of limitation are inapplicable to the state unless the statute specifically provides that the time limit applies to the state.
The Court of Appeals of Ohio affirms the trial court's refusal to reopen the estate, holding that the state's claim for reimbursement is barred by clear statutory language that imposes a one-year statute of limitations on the filing of Medicaid reimbursement claims.
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