493 Mass. 148
Mass.2023Background
- Frances R. Mason received Medicaid-covered long-term care from MassHealth and, in 2008, MassHealth placed a TEFRA lien on her home, anticipating permanent institutionalization.
- Mason died in August 2008, leaving the home unsold and subsequently her estate was not probated until 2017, nearly nine years later.
- In 2018, MassHealth filed a claim against Mason's estate to recover Medicaid benefits paid for her care; the property was sold in 2021.
- The personal representative did not object, but another interested party moved to strike MassHealth's lien and claim.
- The Probate and Family Court struck the TEFRA lien (finding it extinguished at death if the property was not sold during Mason's life) and dismissed MassHealth’s claim (finding it barred by the Massachusetts Uniform Probate Code (MUPC) three-year statute of repose).
- MassHealth appealed, and the Massachusetts Supreme Judicial Court transferred the case for review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can MassHealth enforce a TEFRA lien after the member's death if the property wasn’t sold during life? | Mason’s estate argued the lien dissolved at death absent a lifetime sale. | MassHealth argued the lien survived death until paid. | MassHealth cannot enforce a TEFRA lien after death unless the property is sold during member’s lifetime. |
| Does the MUPC three-year statute of repose bar MassHealth’s claim against an estate if member died before MUPC's effective date? | Dismiss claim as untimely under MUPC statute of repose. | Claim is timely under pre-MUPC statute allowing 50 years. | MUPC statute of repose does not apply retroactively; MassHealth’s claim is timely. |
Key Cases Cited
- Conservation Comm'n of Norton v. Pesa, 488 Mass. 325 (standard of statutory construction review)
- Harvard Crimson, Inc. v. President & Fellows of Harvard College, 445 Mass. 745 (plain-language statutory interpretation)
- Sharris v. Commonwealth, 480 Mass. 586 (plain-meaning and legislative intent)
- Kendall, 486 Mass. 522 (Medicaid estate recovery and statutes of repose)
- Metcalf v. BSC Group, Inc., 492 Mass. 676 (agency deference and statutory construction)
- Daley v. Secretary of the Exec. Office of Health & Human Servs., 477 Mass. 188 (Medicaid rules and state-federal coordination)