ELEANOR BEZZINI v. DEPARTMENT OF SOCIAL SERVICES, 49 Conn.
App. 432 (1998)
Schaller, Spear and Sullivan, Js.
Argued January 21 - officially released July 21, 1998
Michael C. Stumo, with whom, on the brief, was Timothy Brignole,
for the appellant (plaintiff).
Peter L. Brown, assistant attorney general, with whom, on the
brief, were Richard Blumenthal, attorney general, and Richard J.
Lynch, assistant attorney general, for the appellee (defendant).
Opinion
SCHALLER, J.
The plaintiff, Eleanor Bezzini, appeals from the judgment of the
trial court upholding the determination of the department of
social services (department) that the plaintiff is ineligible for
Title XIX medical
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assistance benefits due to a transfer of assets. The principal
issue is whether a transfer of assets from the plaintiff's spouse
to beneficiaries other than the plaintiff, taking effect upon the
death of the spouse, pursuant to the terms of a revocable inter
vivos trust, renders the plaintiff ineligible for Title XIX
medicaid benefits. We affirm the judgment of the trial court.
The relevant facts found by the fair hearing officer are
essentially undisputed. On March 11, 1993, the plaintiff's
spouse, Charles Bezzini, who had been diagnosed with prostate
cancer, established a revocable inter vivos trust, naming himself
as the sole beneficiary during his lifetime. Charles Bezzini
named the couple's two sons, Guy Bezzini and Robert Bezzini, as
the trustees and sole beneficiaries of the trust. The trust
contained no provisions for the care and maintenance of the
plaintiff. Charles Bezzini's will left all residuary property in
his estate to the trust to be distributed in accordance with its
terms.
In April, 1993, the plaintiff began receiving adult day care
services at Jefferson House. Title to Charles Bezzini's home was
transferred to the trust in May, 1993. During May, 1993, Charles
Bezzini transferred all of the couple's remaining assets to the
trust. On June 3, 1993, Charles Bezzini died. The gross value of
Charles Bezzini's estate for succession tax purposes was
determined to be $469,142.80. Pursuant to the terms of the trust,
all assets of the trust were distributed to his two sons.
The plaintiff was cared for at home until October 8, 1993, when
she was admitted to Fenwood Manor, a nursing home. She was
discharged from Fenwood Manor on May 4, 1994, having incurred
expenses of $33,088. The plaintiff is currently a resident of
Riverside Health Center. She applied for Title XIX benefits on
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February 9, 1994. By preliminary decision dated February 17,
1994, the department denied the application on the basis that a
disqualifying transfer of all of the couple's assets occurred on
June 3, 1993, within the thirty month "look back
period" established by department regulations. The
department determined that the plaintiff's ineligibility period
began on June 3, 1993, and extended for thirty months. The fair
hearing officer upheld the determination, concluding:
"[Charles Bezzini] established a revocable trust in March,
1993. The assets at the time of the inception of the trust and
for Title XIX eligibility purposes would not be divided, but
rather totaled against such assistance limits. Upon the death of
the spouse all of the assets due the assistance unit were
transferred without receipt of fair value."
The plaintiff appealed the decision to the Superior Court
pursuant to General Statutes § 4-183. The trial court upheld the
department's decision, concluding that the distribution of assets
pursuant to the trust upon Charles Bezzini's death constituted a
disqualifying transfer of assets without receipt of fair market
value within the thirty month "look back period" from
the date of the plaintiff's application for Title XIX benefits.
The trial court also determined that the fair hearing officer
properly found that Charles Bezzini's intent, at least in part,
was to qualify the plaintiff for medicaid benefits.
The plaintiff presents the following arguments in support of her
position: (1) Because Charles Bezzini died prior to the
plaintiff's application and all of his assets were distributed to
persons other than the plaintiff, there were no assets of a
spouse "living with" the plaintiff that could be
"deemed" to the plaintiff; (2) the distribution of
trust assets that occurred upon Charles Bezzini's death did not
constitute a "transfer" because, upon his death, the
assets passed to the beneficiaries when his interest terminated
by reason of death; and (3)
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the transfer of asset rules do not apply to a postmortem
distribution of property by means of a will and, by analogy, by a
revocable trust.
At the outset, we note our standard of review for all of the
plaintiff's claims on appeal. Because we are reviewing the
decision of an administrative agency, our review is highly
deferential. See Neri v. Powers, 3 Conn. App. 531, 537, 490 A.2d
528, cert. denied, 196 Conn. 808, 494 A.2d 905 (1985); see also
General Statutes § 4-183 j). "Ordinarily, this court
affords deference to the construction of a statute applied by the
administrative agency empowered by law to carry out the statute's
purposes. . . . [A]n agency's factual and discretionary
determinations are to be accorded considerable weight by the
courts. . . . Cases that present pure questions of law, however,
invoke a broader standard of review than is ordinarily involved
in deciding whether, in light of the evidence, the agency has
acted unreasonably, arbitrarily, illegally or in abuse of its
discretion. . . . Furthermore, when a state agency's
determination of a question of law has not previously been
subject to judicial scrutiny . . . the agency is not entitled to
special deference. . . . (I]t is for the courts, and not
administrative agencies, to expound and apply governing
principles of law. . . . Connecticut Light & Power Co. v.
Texas-Ohio Power, Inc., 243 Conn. 635, 642-43, 708 A.2d 202
(1998)." (Internal quotation marks omitted.) Connecticut
Assn. of Not-for-Profit Providers for the Aging v. Dept. of
Social Services, 244 Conn. 378, 389, 709 A.2d 1116 (1998).
In addition, we note the general framework of the medicaid
program. "The federal medicaid program was enacted in 1965
as a cooperative federal-state endeavor designed to provide
health care to needy individuals. 42 U.S.C. § 1396 et seq.;
Atkins v. Rivera, 477 U.S. 154, 156, 106 S. Ct. 2456, 91 L. Ed.
2d 131 (1986). The program provid[es] federal financial
assistance to States that
Page 437
choose to reimburse certain costs of medical treatment for needy
persons. Harris v. McRae, 448 U.S. 297, 301, 100 S. Ct. 2671, 65
L. Ed. 2d 784, reh. denied, 448 U.S. 917, 101 S. Ct. 39, 65 L.
Ed. 2d 1180 (1980). Clark v. Commissioner, 209 Conn. 390, 394,
551 A.2d 729 (1988). States are not required to participate in
the program, but once a state chooses to adopt the program it
must establish a plan conforming with the requirements of the
federal statute. Id. Connecticut has elected to participate in
the program and has assigned to the department the task of
administering the program. General Statutes [Rev. to 1993] §
17-134a et seq.(fn1) Matarazzo v. Rowe, 225 Conn. 314, 319, 623
A.2d 470 (1993).
"As originally enacted [the] Medicaid [Act] required
participating States to provide medical assistance to
categorically needy individuals who received cash payments under
one of four welfare programs established elsewhere in the Act. .
. . The categorically needy were persons whom Congress considered
especially deserving of public assistance because of family
circumstances, age, or disability. States, if they wished, were
permitted to offer assistance also to the medically needy -
persons lacking the ability to pay for medical expenses, but with
incomes [or resources] too large to qualify for categorical
assistance. Schweiker v. Gray Panthers, 453 U.S. 34, 37, 101 S.
Ct. 2633, 69 L. Ed. 2d 460 (1981). [Matarazzo v. Rowe, supra, 225
Conn. 319.] Connecticut has chosen to cover the medically
needy." (Internal quotation marks omitted.) Forsyth v. Rowe,
226 Conn. 818, 823-24, 629 A.2d 379 (1993).
Page 438
I
The plaintiff first claims that her husband's assets in the
revocable trust could not be "deemed" to her because,
at the time she applied for medicaid assistance, Charles Bezzini
was deceased and, therefore, was not "living with" her.
The state responded to this claim at oral argument by indicating
that the "deeming" regulation is irrelevant because the
sole reason the plaintiff was disqualified from receiving
medicaid benefits was due to the transfer of assets by her spouse
without the receipt of fair market value. Thus, no assets of her
spouse were "deemed" to her as the basis for denying
her eligibility. We agree with the state.
The hearing officer based his determination on the specific
language of the transfer of assets provision in the department's
regulations, not the spousal "deeming" provisions. In
addition, both the department and the trial court, in affirming
the hearing officer's determination, relied principally on the
specific language of the transfer of assets provision. In
addition, the plaintiff never raised this claim before the
department or the trial court.
Federal law provides the basic guideline to the states concerning
ineligibility for Title XIX assistance based on a disqualifying
transfer of assets. "[T]he State plan must provide for a
period of ineligibility for nursing facility services . . . in
the case of an institutionalized individual . . . who, or whose
spouse, at any time during or after the 30-month period
immediately before the date the individual becomes an
institutionalized individual . . . or . . . the date the
individual applies for such assistance while an institutionalized
individual, disposed of resources for less than fair market
value." (Emphasis added.) 42 U.S.C. § 1396p (c) (1). Thus,
the federal statute specifically directs the state to formulate
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a period of ineligibility that includes any transfers by the
applicant's spouse.
The department's implementing regulations provide that
"[transfers of assets which affect eligibility are those
which are made by an institutionalized individual or his or her
spouse . . . ." (Emphasis added.) Dept. of Income
Maintenance, Uniform Policy Manual (1992) § 3027.05 (C). This
regulation's General Statement also supports our conclusion.
"There is a period established . . . during which
institutionalized individuals are not eligible for certain
Medicaid services when they or their spouses dispose of assets
for less than fair market value within certain time limits."
(Emphasis added.) Id., § 3027.05 (A). Thus, for determining
ineligibility based on a transfer of assets without the receipt
of fair market value, both the federal statute and the
department's regulations explicitly include transfers made by a
spouse. We conclude, therefore, that the regulations concerning
the deeming of assets between spouses are not relevant to this
case because the transfer of asset rules accomplish the same
objective without resort to the legal fiction of
"deeming."
II
The plaintiff next claims that the distribution of assets from
the revocable trust that occurred on June 3, 1993, did not
constitute a "transfer of assets" under the medicaid
statutes and regulations because on the date of death, the
plaintiff's spouse did not have a property interest that he could
transfer. In essence, the plaintiff contends that by funding a
revocable trust with assets, with no fair market value received
in exchange, those assets are immunized from the medicaid penalty
provisions. We are not persuaded.
The fair hearing officer determined that the transfer of assets
occurred on June 3, 1993, the date on which the plaintiff's
spouse died, when he no longer could
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exert any control over the assets in the revocable trust. This
conclusion is correct because at any time until his death, the
plaintiff's spouse could have revoked the trust and thereby
gained access to all of the assets in the trust. Prior to his
death, Charles Bezzini's assets in the revocable trust could have
been "deemed" to the plaintiff, if she had applied for
medicaid. See id., § 4025.65 (A). At the time of his death, the
transfer occurred because, for the first time, the assets passed
out of his control. Since that transfer occurred within the
thirty month period, the assets in the trust are recaptured by
the look back provisions. It would, therefore, be incorrect to
conclude that the transfer of assets occurred prior to Charles
Bezzini's death because legal title did not pass irrevocably.
This position is supported generally by our case law concerning
property transfers via revocable trusts. See Bartlett v.
Bartlett, 220 Conn. 372, 376-77, 599 A.2d 14 (1991) (beneficiary
of revocable trust does not have vested property interest, but
rather mere expectancy, until death of settlor renders trust
irrevocable); Rubin v. Rubin, 204 Conn. 224, 230-32, 527 A.2d
1184 (1987) (same); see also Dalia v. Lawrence, 226 Conn. 51, 60,
627 A.2d 392 (1993) (beneficiary of trust savings account, Totten
trust, does not acquire legal interest in funds on deposit until
death of settlor); Salvio v. Salvio, 186 Conn. 311, 322-24, 441
A.2d 190 (1982) (same).
We conclude, therefore, that the transfer of assets occurred upon
the death of the plaintiff's spouse by virtue of the trust. A
termination of his interest in the trust is equivalent to a
transfer to the beneficiaries. The assets distributed according
to the terms of the trust are "brought back" from the
beneficiaries for consideration for this purpose if the transfer
occurred within the thirty months preceding the application for
Title XIX benefits. The fact that the plaintiff's spouse had died
and the assets had been disposed of prior to the application
Page 441
does not save them from being considered as existing assets of a
spouse. To conclude otherwise would create an exception to the
medicaid qualification rules whereby an applicant could avoid the
transfer of assets provisions simply by establishing a revocable
trust. This result clearly would be contrary to the legislative
purpose underlying the medicaid program.(fn2)
Our Supreme Court's decision in Forsyth v. Rowe, supra, 226 Conn.
818, is instructive. In Forsyth, the court concluded that a trust
that was established for the purpose of assisting an incompetent
beneficiary with the proceeds from a tort recovery constituted a
medicaid qualifying trust that served to disqualify the
applicant. Id., 829-30. While that case is factually different
from the present case, our Supreme Court's recitation of the
policies behind enforcement of the medicaid qualification rules
is pertinent to this case. "Our conclusion reflects the
legislative concern that the medicaid program not be used as an
estate planning tool. The
Page 442
medicaid program would be at fiscal risk if individuals were
permitted to preserve assets for their heirs while receiving
medicaid benefits from the state. Congress enacted the medicaid
qualifying trust provision as an addition to the 'provisions
designed to assure that individuals receiving nursing home and
other long-term care services under Medicaid are in fact poor and
have not transferred assets that should be used to purchase the
needed services before Medicaid benefits are made available.' H.
Rep. No. 99-265, 99th Cong., 1st Sess. 71 (1985)." Forsyth
v. Rowe, supra, 828-29.
The policy considerations articulated in Forsyth are applicable
to this case, despite the fact that a medicaid qualifying trust
is not present in this case. Accordingly, we conclude that the
distribution of trust assets that occurred upon the death of the
plaintiff's spouse constituted a transfer of assets under the
medicaid rules that served to disqualify the plaintiff from
receiving benefits.
III
The plaintiff claims finally that the transfer of asset rules do
not apply to the postmortem distribution of property through a
will, and by analogy they should not apply in this case to the
Charles Bezzini trust, which was a will substitute. Specifically,
the plaintiff claims that her spouse's revocable trust was an
equitable testamentary instrument that provided for their
children postmortem. Since the trust served the same function as
a will, to pass property to beneficiaries postmortem, the law of
wills should be applied to this situation to determine the
plaintiff's eligibility for medicaid assistance. We disagree.
A will is a unique kind of transfer, with special rules
associated with the proper execution and administration thereof.
Barnes v. Viering, 152 Conn. 243, 246, 206 A.2d 112 (1964); Crane
v. Manchester, 143 Conn. 498,
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500-501, 123 A.2d 752 (1956). The creation of a revocable trust
is not a testamentary act and need not conform to the
requirements of the common-law statute of wills. Cramer v.
Hartford-Connecticut Trust Co., 110 Conn. 22, 33-34, 147 A. 139
(1929). Under a will, a spouse need only claim the spousal share
if disinherited; see General Statutes § 45a-436; DelVecchio v.
DelVecchio, 146 Conn. 188, 192-93, 148 A.2d 554 (1959).
Alternatively, a spouse is unable to claim a spousal share
against a trust. Cherniack v. Home National Bank & Trust Co.,
151 Conn. 367, 370-71, 198 A.2d 58 (1964). The fact that the
intent of the settlor may have encompassed several goals,
including avoiding probate and eliminating estate administration
expense, cannot evade a finding that one purpose was to qualify
his spouse for medicaid benefits by improper means. The fact that
the department could have drafted specific rules for inter vivos
trusts applicable at that time does not preclude a determination
that this transfer was improper under existing rules. We
conclude, therefore, that the rules applicable to wills should
not be applied to the plaintiff's situation where a revocable
trust was the chosen instrument of the plaintiff's spouse.
The judgment is affirmed.
In this opinion the other judges concurred.
__________
Footnotes:
1 General Statutes (Rev. to 1993) § 17-134a provides in relevant
part: "The commissioner of income maintenance is authorized
to take advantage of the medical assistance programs provided in
Title XIX, entitled 'Grants to States for Medical Assistance
Programs,' contained in the Social Security Amendments of 1965
and may administer the same in accordance with the requirements
provided therein . . . ."
General Statutes (Rev. to 1993) § 17-134d provides in relevant
part: "The commissioner of income maintenance may make such
regulations as are necessary to administer the medical assistance
program. . . ."
2 Our review of the department's current regulations reveals
further support for the department's conclusion that the
plaintiff was ineligible for medicaid assistance benefits. Dept.
of Income Maintenance, Uniform Policy Manual (1993) § 4030.80
(B) (2), addresses the treatment of specific types of trusts and
provides: "The funds in an inter vivos trust created on or
after October 1, 1992, but prior to August 11, 1993, are
considered available to an individual or the individual's spouse
if:
"a. the individual or the individual's spouse is the settlor
of the trust; and
"b. the individual or the individual's spouse is a
beneficiary of the trust; and
"c. the individual applies for cash or Medicaid within 30
months subsequent to the establishment of the trust."
While this regulation was not effective at the time the trust was
established, it was effective at the time the plaintiff applied
for benefits. The Charles Bezzini Revocable Trust was created
within the relevant time period. The plaintiff's spouse was the
lifetime beneficiary of the trust. The plaintiff applied for
medicaid assistance benefits on February 9, 1994, within eleven
months of the establishment of the trust. All of the elements of
the department's regulation have been satisfied. As a result, the
assets in the revocable trust would be considered available to
the plaintiff as part of her medicaid application, thereby
serving to disqualify her from receiving benefits. This
regulatory provision, therefore, provides further support for the
department's decision to disqualify the plaintiff from receiving
benefits.