J.F. VS. DIVISION OF MEDICAL ASSISTANCE AND HEALTH SERVICES (DIVISION OF MEDICAL ASSISTANCE AND HEALTH SERVICES), A-0807-17T4

In April 2015 J.F., through his daughter and power of attorney M.P., applied for Medicaid with the Camden County welfare agency (CWA). The CWA requested five years of checking‑account statements to verify eligibility and set deadlines for submission.
M.P. sought and received one extension; she later submitted a bank receipt showing the account was closed in January 2015 with a final balance of $19.16 but did not provide the requested historical statements or seek a further extension.
The CWA denied the application in July 2015 for failure to provide verification documents under N.J.A.C. 10:71‑2.2(e)(2). J.F. requested a fair hearing.
At hearing, J.F. argued (1) the submitted receipt was sufficient to verify eligibility and (2) the agency violated state and federal law by failing to assist in obtaining financial records (including by electronic means such as the Asset Verification System (AVS)).
The ALJ found the CWA was not required to assume the applicant’s obligation to obtain documents and that the receipt was insufficient given the sixty‑month look‑back rule; the Director adopted the ALJ’s decision and denied benefits. J.F. appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the submitted bank receipt was sufficient to verify eligibility	The receipt showing the account closed with $19.16 was adequate to establish financial status	The receipt did not permit verification of transfers during the 60‑month look‑back period; full statements were required	Held: Receipt insufficient; agency reasonably required full verification to examine transfers during look‑back
Whether the CWA violated state or federal law by failing to assist in obtaining bank records (e.g., via AVS)	CWA should have assisted and obtained records electronically or otherwise under state/federal verification obligations	CWA fulfilled its duties: it extended deadlines, AVS was not yet operational, and regulations do not obligate the agency to substitute for the applicant in producing bank records	Held: No violation; agency actions were consistent with N.J. regulations and federal rules and not arbitrary or unreasonable

Allstars Auto Grp., Inc. v. N.J. Motor Vehicle Comm'n, 234 N.J. 150 (standard of review for agency decisions)
Stallworth, 208 N.J. 182 (deference to agency factfindings and application of law)
Harris v. McRae, 448 U.S. 297 (federal requirements for state compliance to receive Medicaid funds)
In re Estate of Brown, 448 N.J. Super. 252 (Medicaid eligibility requires meeting income and resource standards)