New York Law Review

Golf v. New York State Dept. of Social Services, 91 N.Y.2d 656 (1998): Interpreting Medicaid Eligibility for Institutionalized Spouses

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The New York Law Review

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Golf v. New York State Dept. of Social Services, 91 N.Y.2d 656 (1998)

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When determining Medicaid eligibility for an institutionalized spouse, state agencies have discretion to use the “income first” method (transferring income to the community spouse before assessing resources) if the governing statutes are ambiguous and the method aligns with the Medicaid program’s policy objectives.

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Summary

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This case addresses whether New York’s Department of Social Services (DSS) properly used the “income first” method to determine Medicaid eligibility for an institutionalized spouse, Floyd Golf, whose wife, Mrs. Golf, applied for benefits after his death. The DSS transferred a portion of Mr. Golf’s income to Mrs. Golf to meet her minimum monthly needs before assessing his resources, leading to a denial of benefits due to excess resources. The Court of Appeals reversed the Appellate Division’s decision, holding that the relevant statutes were ambiguous and allowed for the “income first” approach, which aligns with the purpose of protecting the community spouse without creating unintended financial benefits.

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Facts

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Floyd Golf entered a nursing home in January 1993. Following his death in August 1993, his wife, Mrs. Golf, sought Medicaid benefits to cover his nursing home expenses for January and February of that year. The Monroe County DSS determined the couple had combined resources of $105,763.60, attributing $86,855.25 to Mrs. Golf and $18,908.35 to Mr. Golf. Mrs. Golf’s minimum monthly maintenance needs allowance was $1,769, but her actual monthly income was only $1,379.06. Mr. Golf had $13,100 in excess resources and a monthly income of $1,319.58.

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Procedural History

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The Monroe County DSS initially denied Medicaid benefits for Mr. Golf, deeming him ineligible because of his excess resources. Mrs. Golf challenged this decision at a fair hearing, arguing for the “resource first” method, but the New York State Department of Social Services upheld the agency’s application of the “income first” method. Mrs. Golf then initiated a CPLR article 78 proceeding, which was initially denied by the Supreme Court. The Appellate Division reversed, favoring the “resource first” method. The Court of Appeals granted leave to appeal directly from the Supreme Court judgment.

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Issue(s)

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1. Whether the applicable federal and state statutes mandate the use of the

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