Posted on Mar 02, 2020

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.

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Michael Monteforte, Jr.
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