Wisconsin Dept. of Health and Family Servs. v. Blumer, 534 U.S. 473 (2002)

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OCTOBER TERM, 2001

Syllabus

WISCONSIN DEPARTMENT OF HEALTH AND FAMILY SERVICES v. BLUMER

certiorari to the court of appeals of wisconsin

No. 00-952. Argued December 3, 2001—Decided February 20, 2002

In developing standards for determining Medicaid eligibility, participating States must "tak[e] into account only such income and resources as are, as determined in accordance with standards prescribed by the Secretary [of Health and Human Services (Secretary)], available to the applicant." 42 U. S. C. 1396a(a)(17)(B) (emphasis added). Because spouses typically possess assets and income jointly and bear financial responsibility for each other, Medicaid eligibility determinations for married applicants have resisted simple solutions. Until the Medicare Catastrophic Coverage Act of 1988 (MCCA or Act), state standards often left a spouse living at home (called the "community spouse") destitute, the couple's assets drained to qualify his or her mate (the "institutionalized spouse") for Medicaid, and the couple's posteligibility income diminished to reduce the amount payable by Medicaid for institutional care. The MCCA's "spousal impoverishment" provisions responded to this problem by including in the Medicaid statute requirements with which States must comply in allocating a couple's income and resources. The Act's income allocation rules direct that, in any month in which one spouse is institutionalized, "no income of the community spouse shall be deemed available to the institutionalized spouse," 1396r-5(b)(1); require States to set for the community spouse a "minimum monthly maintenance needs allowance" (MMMNA), 1396r-5(d)(3); and prescribe that, if the community spouse's posteligibility income is insufficient to yield income equal to or above the MMMNA, the shortfall—called the "community spouse monthly income allowance" (CSMIA)—may be deducted from the institutionalized spouse's income and paid to the community spouse, 1396r-5(d)(1)(B). The MCCA's resource allocation rules provide, inter alia, that, in determining the institutionalized spouse's Medicaid eligibility, a portion of the couple's resources—called the "community spouse resource allowance" (CSRA)—shall be reserved for the benefit of the community spouse, 1396r-5(c)(2). To calculate the CSRA, the couple's jointly and separately owned resources are added together as of the time the institutionalized spouse's institutionalization commenced; half of that total, subject to certain limits, is then allocated to the community spouse, 1396r-5(c)(1)(A), (2)(B), (f)(2)(A), (g). The CSRA is deemed unavailable to the institutionalized

473

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