MAOA v Sharp

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First Circuit

Mass. Assoc. Older Americans (MAOA) v. Sharp, 700 F.2d 749 (1st Cir. 1983) reversing and remanding lower court order denying injunctive relief to plaintiffs whose Medicaid was terminated Contempt order upholding remedial order of lower court and finding that agency was in contempt.  803 F. 2d 35 (1st Cir. 1986). State-wide class action involving a number of application issues in the administration of the state Medicaid program, including issues of application delay and automatic termination of Medicaid recipients when found no longer eligible for financial assistance. Class certified but preliminary injunctions denied by lower court. On February 15, 1983, the First Circuit held that the Department could not automatically terminate Medicaid benefits for families who lost AFDC benefits because of the new AFDC stepparent deeming provisions. On May 25, 1983, a permanent injunction issued in all Medicaid automatic termination cases. On 10/15/86, First Circuit upheld order of contempt. DPW now required to give all SSI-related Medicaid clients four months for any redetermination. 

Since MAOA v Sharp, the single welfare department that administered both Medicaid and cash welfare assistance split into two separate agencies and the Medicaid agency modified the relief for people terminated by the welfare agency. As now applied by MassHealth, the "MAOA" process provides for four months of extended MassHealth Standard coverage for people who lose TAFDC or EAEDC cash assistance before MassHealth sends them a renewal application so long as they are "potentially eligible" for MassHealth Standard. 130 CMR 505.002(L).  At the end of the extended period, MassHealth independently reviews eligibility. People terminated from cash assistance for reasons that would also make them ineligible for MassHealth such as a move out of state, do not receive the 4 month extension. 

EAEDC recipients enrolled in CarePlus or Family Assistance, remain eligible after their EAEDC ends until determined ineligible by MassHealth. The regulations do not mention 4 months of extended eligibility for them. 130 CMR  505.008(B)(2) (CarePlus) and 505.005(G)(2) (Family Assistance).