Elliot v. North Carolina Department of Human Resources

Judge John

dissenting.

I dissent for the reasons stated by Judge (now Chief Judge) Arnold in Kempson v. N.C. Dept. of Human Resources, 100 N.C. App. 482, 397 S.E.2d 314 (1990), aff’d, by an equally divided Court, 328 N.C. 722, 403 S.E.2d 279 (1991). In Kempson we held that “DHR must employ the resource spend-down methodology when determining Medicaid eligibility . . . .” Id. at 489, 397 S.E.2d at 318. Although Kempson is without precedential authority, the reasoning contained therein is sound and consistent with both federal and state legislation. Consequently, I would adopt the Kempson rationale and hold that DHR is required to utilize “resource spend-down” in determining an individual’s eligibility for Medicaid payments.

*624Denial of Medicaid benefits to one whose total assets exceed the allowable limit, yet who has already become obligated to pay medical bills far in excess of that individual’s total assets, contravenes the legislative purpose underlying both the Federal and North Carolina medical assistance acts. As the majority points out, federal and state programs were established' to furnish assistance to those whose income and resources are insufficient to meet the costs of necessary medical care. The rigidly bureaucratic interpretation urged by respondent DHR ignores the remedial status of our medical assistance legislation. As such, it must be “liberally construed so that the beneficial purpose intended by [its] enactment may be accomplished.” Sutton v. Aetna Casualty & Surety Co., 325 N.C. 259, 265, 382 S.E.2d 759, 763, reh’g denied, 325 N.C. 437, 384 S.E.2d 546 (1989). As aptly stated by Judge Lewis in a recent dissent, “[w]hen the literal interpretation of a statute contravenes the manifest purpose of the statute, the reason and purpose of the law will be given effect and the strict letter of the statute will be disregarded.” State v. Williams, 113 N.C. App. 686, 694-95, 440 S.E.2d 324, 328 (1994) (Lewis, J., dissenting).

For the aforementioned reasons, I respectfully dissent.