MassHealth Must Construe Federal Medicaid Law to Favor Applicants, and Cannot Be More Restrictive Than SSI

The Medicaid Act at 42 U.S.C. §1396a(a)(19) requires that each state Medicaid program be administered in the “best interests of the recipients,” and both the federal Medicaid law and its implementing regulations must be construed in favor of the Medicaid beneficiary. “The Social Security Act, of which Medicaid is a part, is in the nature of remedial legislation and is to be liberally construed.” See Cristy v. Ibarra, 826 P.2d. 361 (Court of Appeals, Co. 1991).

The MassHealth fact-finding process and trust law interpretation in this case is more restrictive than Supplemental Security Income (SSI) Program procedures. The MassHealth agency cannot utilize a methodology that is more restrictive than that used by SSI. See 42 U.S.C. § 1396a(a)(10)(C)(i)(III). A methodology is “considered to be ‘no more restrictive’ if, using the methodology, additional individuals may be eligible for medical assistance and no individuals who are otherwise eligible are made ineligible for such assistance.” 42 U.S.C. §1396a(r)(2)(B).