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Matter of Estate of Mason, 493 Mass. 148, 222 N.E.3d 1082, Med & Med GD (CCH) P 307,913

Facts

Frances R. Mason, a nursing facility resident, received Medicaid benefits from MassHealth from January to August 2008. A TEFRA lien was recorded against her home in South Yarmouth on May 2, 2008, due to her permanent institutionalization. Mason died on August 18, 2008, without selling the property while alive. In June 2017, nearly nine years after her death, the named executor of her will filed a petition to open probate proceedings, leading to MassHealth's claim for recovery of Medicaid benefits paid for Mason's care.

The relevant facts are undisputed. From January to August 2008, MassHealth provided Medicaid funds to cover Mason's care in a residential nursing facility. On May 2, 2008, MassHealth, having determined that Mason would be institutionalized permanently, recorded a TEFRA lien against Mason's home in South Yarmouth (property).

Issue

Whether MassHealth can enforce a TEFRA lien against a Medicaid recipient's property after the recipient's death, and whether the three-year statute of repose of the Massachusetts Uniform Probate Code applies retroactively to bar MassHealth's claim.

The first question on appeal: whether, having placed a TEFRA lien against the property of a member who is permanently institutionalized, MassHealth may enforce the TEFRA lien after the member's death.

Rule

MassHealth is generally prohibited from recovering Medicaid benefits paid until after a member's death, except under specific circumstances, such as the imposition of a TEFRA lien during the member's lifetime.

In Massachusetts, the Legislature has codified the general prohibition against imposing liens during a member's lifetime other than as expressly authorized by the Medicaid Act; accordingly, it permits MassHealth to impose TEFRA liens.

Analysis

The court analyzed the statutory framework governing TEFRA liens and concluded that while MassHealth may impose a lien during a member's lifetime, the enforcement of such a lien is not permitted after the member's death. The court also determined that the statute of repose does not retroactively bar MassHealth's claim against the estate, as the claim is based on the Medicaid benefits paid, which are recoverable from the estate post-death.

We reject MassHealth's assertion that while G. L. c. 118E, § 31 (d), governs when MassHealth may enforce a TEFRA lien during a member's lifetime, the statute's silence as to whether a TEFRA lien also may be enforced as part of the estate recovery program implicitly permits such recovery.

Conclusion

The court affirmed the Probate and Family Court's decision to strike MassHealth's lien against Mason's home but reversed the dismissal of MassHealth's claim against her estate, allowing the claim to proceed.

We affirm the order of the Probate and Family Court judge insofar as it struck MassHealth's lien against the home of the decedent, Frances R. Mason, who was permanently institutionalized in a medical facility in the last months of her life, and we reverse the order insofar as it dismissed MassHealth's claim against her estate.

Who won?

MassHealth prevailed in part, as the court allowed its claim against Mason's estate to proceed, emphasizing that the statute of repose does not apply retroactively to bar such claims.

MassHealth maintains that G. L. c. 118E, § 32 (j), MassHealth contends that the Legislature broadly contemplated the disposition of TEFRA liens in connection with the member's estate.

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