Communicare v. Ohio Dept. of Job & Family Servs.

Citations

• 2019 Ohio 3757

Syllabus

Authorized representative administrative appeal application for Medicaid benefits countable resources eligibility limit real property. A trial court does not abuse its discretion where it applies the definition from the applicable provision of the Administrative Code rather than a definition from an unrelated federal regulation, and thereby finds the agency's decision was supported by reliable, probative and substantial evidence. Where the value of applicant's real property exceeds the Medicaid resource limit the application is properly denied. Regardless of whether a trial court errs by determining that an applicant's authorized representative does not have standing to challenge denial of Medicaid benefits, where there is no prejudice the error is harmless. A trial court does not abuse its discretion where it affirms the agency's denial of an application for Medicaid benefits where the applicant owns resources that exceed the Medicaid eligibility limit, regardless of whether the applicant has outstanding property that has not been verified. Where an applicant for Medicaid benefits owns resources that exceed the Medicaid eligibility limit the status of any incomplete verification is moot.