New Jersey appeals court affirmed denial of Medicaid application for failure to verify recurring bank transactions on applicant’s bank statements even though the transactions may have been part of a scam. G.M. v. Division of Medical Assistance and Health Services (N.J. Super. Ct., App. Div., No. A-0433-19, June 16, 2021).

G.M. was eighty-three years old, suffered from dementia, and was permanently institutionalized in a nursing home. In 2018, she applied for Medicaid benefits and submitted the required proofs and bank statements. The Medicaid agency requested verification of the source and purpose of recurring transactions appearing on petitioner’s 2013 bank statements labelled, “ACH DEPOSIT UNITEDCAPITALCRE UNITED CAP” (UCC), in the amount of $300. The transactions included debits and credits to and from petitioner’s account. G.M.’s authorized representative told the agency that G.M.’s family believed the UCC transactions were part of a scam that G.M.  was a victim of, and she provided computer screenshots indicating UCC was no longer in business, and therefore, she was unable to provide formal documentation detailing petitioner’s UCC transactions.

G.M.’s application for Medicaid benefits was denied because she failed to provide sufficient verification of the UCC transactions. G.M. requested a fair hearing. At the hearing, the Medicaid agency representative acknowledged that the UCC was a defunct collection agency. The ALJ issued an initial decision affirming the denial of petitioner’s Medicaid eligibility, stating that there was a lack of evidence that G.M.’s agent under her power of attorney attempted to determine the nature of the transactions. The Medicaid agency affirmed the denial, and G.M. appealed to court.

The New Jersey Superior Court, Appellate Division, affirmed the decision denying benefits, holding that the Medicaid agency properly denied G.M.’s Medicaid application for failure to provide verifications. According to the Court, the computer screenshots of UCC’s former website did not provide evidence of the purpose of the transactions The Court held that “Because the [Medicaid agency] is tasked with ensuring that applicants have below $2000 in resource levels, and petitioner’s proof of eligibility was inconclusive, the Division’s decision to deny petitioner’s application was not arbitrary, capricious, or unreasonable.”

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