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Hopkins v. DHS
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MAINE SUPREME JUDICIAL COURT Reporter of Decisions
Decision: 2002 ME 129
Docket: Cum-02-101
Argued: June 13, 2002
Decided: August 8, 2002
Panel: SAUFLEY, C.J., and CLIFFORD, RUDMAN, DANA, ALEXANDER, CALKINS, and
LEVY, JJ.
ROY AND PATRICIA HOPKINS
v.
DEPARTMENT OF HUMAN SERVICES
RUDMAN, J.
[¶1] Roy and Patricia Hopkins appeal from the judgment entered in the
Superior Court (Cumberland County, Crowley, J.) affirming the decision of the
Department of Human Services (DHS) to terminate their Medicaid benefits. The
Hopkins contend (1) that DHS failed to provide them with adequate notice of the
reasons behind the termination as required by federal regulations and DHS rules
of procedure, and (2) that this failure deprived them of their constitutionally
protected due process rights. We disagree and affirm the judgment.
I. STATEMENT OF THE CASE
[¶2] Roy and Patricia Hopkins suffer from serious health problems and
must undergo extensive medical treatment, the combined cost of which is
estimated to be $2527.48 per month. The Hopkinses are unable to work and must
rely on Social Security as their only source of income. This income amounts to a
combined $2368.50 per month.{1} Over the past few years, the Hopkinses have
received full Medicaid coverage.
[¶3] In a letter dated September 12, 2000, DHS informed the Hopkinses
that their Medicaid benefits would terminate on March 31, 2001 and that their
medical expenses between October 2000 and March 2001 would have to exceed
$6477 (the deductible) before they received any further Medicaid assistance. The
letter stated that the reason for the termination was because the Hopkinses'
countable monthly income was greater than the allowable limit. The letter also
cited various sections of the Maine Medicaid Eligibility Manual (MMEM),
and included information about Medicaid availability for their children (Cub
Care), their right to a hearing, and possible legal assistance. Me. Medicaid
Eligibility Manual, 10 144 CMR 332 (Weil 2001).
[¶4] Because the Hopkinses requested a fair hearing, DHS provided them
with a "Fair Hearing Report." The report once again informed them that their
Medicaid benefits were being terminated because their income exceeded the
allowable limit. Although the report cited some general sections of the MMEM
which pertained to income, it failed to provide an explanation as to how their
income was calculated.
[¶5] The hearing was held on November 16, 2000. During the hearing,
DHS clearly explained how it calculated the Hopkinses' income and the
deductible. The hearing officer upheld the DHS decision to terminate the
Hopkinses' benefits. The officer's decision stated that the reason for the
termination of benefits was because the Hopkinses' monthly income exceeded the
maximum allowable limit. The decision also provided a more specific
explanation of how their income and deductible were calculated. The Hopkinses,
pursuant to M.R. Civ. P. 80C, appealed the decision to the Superior Court.
[¶6] The court, in a well-reasoned opinion, affirmed the decision of the
hearing officer. The court determined that the Fair Hearing Report was defective
in that it failed to provide information about how their income was calculated and
that it cited general, rather than specific, sections of the MMEM. Nevertheless,
the court found that the Hopkinses were not prejudiced by these omissions and
noted that "there has been no assertion that additional preparation could have
changed the outcome of the hearing - the [Hopkinses] receive too much unearned
income, and therefore must be put on the deductible plan." The Hopkinses filed
this appeal.{2}
II. DISCUSSION
A. The Notice
[¶7] Medicaid is a federal/state cooperative program designed to provide
for the medical expenses of low income households. Before a state receives
federal funding under this program, it must create a state plan which describes
"the nature and scope" of its specific Medicaid program. 42 C.F.R. |