Supreme Court
Tex. Health & Hum. Servs. Comm’n v. Estate of Burt
- Case number: 22-0437
- Legal category: Administrative Law
- Subtype: Judicial Review
- Set for oral argument: October 4, 2023
Case Summary
At issue in this case is whether the Texas Health and Human Services Commission reasonably interpreted the Medicaid “home” exclusion as requiring applicants asserting the exclusion to have previously occupied the property.
The Burts purchased a home in Cleburne, Texas. After living there for thirty-six years, they sold the Cleburne home to their adult daughter and moved into a rental property. In early August 2017, the Burts moved to a skilled nursing facility. At that time, their bank account balance exceeded the eligibility threshold for Medicaid benefits. However, later that month, the Burts purchased a one‑half interest in the Cleburne home, depleting their bank account balance to $2,000. The same day, the Burts deeded their newly acquired half‑interest back to their daughter while reserving an enhanced life estate in the property.
The Burts then applied for Medicaid. HHSC denied their application, concluding that the Burts’ resources exceeded the Medicaid resource limit. HHSC concluded that under the applicable regulation, the Burts’ partial ownership interest in the Cleburne home could not be excluded from the resource calculation because they never resided in the home while having an ownership interest.
After exhausting their administrative remedies, the Burts sought judicial review. The trial court reversed, holding that HHSC unreasonably interpreted the home exemption to require prior occupancy. HHSC appealed, and the court of appeals affirmed.
In its petition for review, HHSC argues that its interpretation of the term “home” as requiring simultaneous ownership and occupancy was reasonable. The Supreme Court granted HHSC’s petition for review.
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