HomeMy WebLinkAbout08-09-06
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT
IN RE: CONSTANCE M. MEREDITH
A/K/A CONSTANCE G. MEREDITH,
AN ALLEGED INCAPACITATED
PERSON
Docket No. 06-0294
PETITION TO TRANSFER REAL ESTATE
AND NOW comes Petitioner, William J. Meredith, by and through his attorney, Marielle
F. Hazen, and files this Petition to transfer real estate and in support hereof avers as follows:
1. By Court Order dated June 12, 2006, William J. Meredith was appointed Plenary
Guardian of the Estate of Constance M. Meredith, a/kJa Constance G. Meredith. Constance M.
Meredith was adjudicated to be incapacitated and unable to manage her financial affairs. A true
and correct copy of the Order is attached hereto as Exhibit "A."
2. Petitioner, William J. Meredith, is the spouse of 51 years of Constance M.
Meredith, and resides at 165 Linn Drive, Carlisle, Pennsylvania, 17013.
3. Constance M. Meredith and William J. Meredith have two children: William R.
Meredith (son), of 404 Pine Grove Road, Gardeners, Pennsylvania, 17324, and Stephen D.
Meredith (son), of 104 West Green Street, 3rd Floor, Mechanicsburg, Pennsylvania, 17055.
4. William J. Meredith and Constance M. Meredith hold an interest irl f_eal prop~Jty
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as tenants by the entireties. The property is located at 165 Linn Drive, Carlisle, PeunSylvarila,
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17013 (hereinafter referred to as "the residence"), and is William J. Meredith's primary
residence.
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5. Constance M. Meredith has been diagnosed with Paranoid Schizophrenia and
Organic Brain Syndrome, and has been adjudicated a totally incapacitated individual with regard
to management of her financial resources. She is currently a patient at the Danville State
Hospital, 200 State Hospital Drive, Danville, Pennsylvania, 17821, and is expected to remain in
a psychiatric hospital or nursing care facility for the rest of her life.
6. Constance M. Meredith is currently paying $651.00 per day for her care. She is
likely to deplete her assets and qualify for Medical Assistance to pay for her care at the Danville
State Hospital within the next few months.
7. William J. Meredith desires to have the residence transferred into his sole
ownership. This transfer would serve to protect the residence for him.
8. William J. Meredith also needs to transfer the couple's remaining assets into his
sole ownership when their assets have been depleted to a level that would allow Constance M.
Meredith to qualify for Medical Assistance.
9. Pennsylvania statute provides that transfers for less than fair consideration do not
result in an ineligibility period when the transfer is made between spouses (attached as Exhibit
"B" is a copy of 55 Pa. C.S.A. ~ 178.101).
10. Constance M. Meredith's countable resources cannot exceed $8,000.00 in order
for her to be eligible for Medical Assistance. Attached as Exhibit "c" is a copy of a blank
Notice fonn from the Department of Public Welfare. This form is sent upon determination of
eligibility for Medical Assistance to advise that all assets exceeding $8,000.00 must be removed
from the nursing home spouse's name or Medical Assistance eligibility will be terminated.
11. Pursuant to the Probate Estate and Fiduciary Code 20 P A C.S.A. 95536 (b) (2),
the Court may substitute its judgment for that of the incapacitated person and authorize estate
planning for the benefit of the incapacitated person or the incapacitated person's family.
2
WHEREFORE, Petitioner requests this Honorable Court to enter an Order, pursuant to
the Probate Estates and Fiduciary Code 20 PA C.S.A. ~5536 (b) (2), authorizing William J.
Meredith, as Guardian of the estate of Constance M. Meredith, alk/a Constance G. Meredith, to
sign a Deed transferring Constance Meredith's interest in that real property located at 165 Linn
Drive, Carlisle, Pennsylvania, 17013 to her spouse, William J. Meredith, and authorize the
transfer of the remaining marital assets to the sole ownership of William J. Meredith so
Constance M. Meredith can qualify for Medical Assistance benefits to pay for her care at the
Danville State Hospital or another care facility.
Respectfully submitted,
Date: y" 'J.- J l..t'
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Marlelle F. zen, Esquire
Attorney ID No. 68003
2000 Linglestown Road, Suite 202
Harrisburg, Pennsylvania 17110
(717)540-4332
Attorney for Petitioner
3
VERIFICATION
I verify that the statements made in this Petition are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities.
.MJ A...e,P~~ ~/YI 0(
WILLIAM J. M DITH
4
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IN RE: CONSTANCE M. MEREDITH : IN THE COURT OF COMMON PLEAS
alkJa CONSTANCE G. MEREDITH: OF CUMBERLAND COUNTY,
: PENNS~ VANIA
: ORPHANS' COURT DIVISION
JUll 8 2llfI6 if'
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An alleged incapacitated person
: NO. 06-0294
On the Petition of WILLIAM J. MEREDITH
AMENDED FINAL ORDER OF COURT
APPOINTING PLENARY GUARDIAN
AND NOW, this ~() ~ day of ~
, 2006, upon Petition by the Guardian
in this matter and a finding that Constance M. Meredith and Constance G. Meredith are the same
person, it is hereby ordered, adjudged and decreed that Constance M. Meredith should be
referred to as Constance M. Meredith, also known as Constance G. Meredith, and the caption in
this matter is amended accordingly.
The Guardian shall have all of the authorities outlined in the original Order dated June
12, 2006. Said Order is attached hereto and made a part hereof as if set forth in full.
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Exhibit" A"
A TRUE COPY FROM RECO,~C
In l:;tor~:~)~~r~~';;~ ,: ,~e~;~I:.:'C
of saia c.ourt at i,Ai. "biO, ;~,(~(r7.tJ
This day of .1~'"(-rrPA ~~
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IN RE: CONSTANCE M. MEREDITH : IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYL VANIA
: ORPHANS' COURT DIVISION
An alleged incapacitated person : NO. 06-0294
On the Petition of WILLIAM J. MEREDITH
FINAL ORDER OF COURT APPOINTING PLENARY GUARDIAN
AND NOW, this '2~dayof J\..U'-lL-
, 2006, a hearing in this case having been .
held on June 12, 2006 at 2:30 p.m., and it appearing to the Court that CONSTANCE M.
MEREDITH was served with a Citation and Notice of this hearing on May 17,2006, and the Court
finds that the physical or mental condition of CONSTANCE M. MEREDITH would be harmed by
her presence at hearing, and further finds from the testimony:
1. That CONSTANCE M. MEREDITH suffers from Paranoid Schizophrenia and
Organic Brain Syndrome, conditions which impair her capacity to receive and evaluate information
effectively and to make and communicate decisions concerning her management of financial affairs
or to meet essential requirements for her physical health and safety.
2. That there are insufficient supports available to assist CONSTANCE M. MEREDITH
in such decisions and that there exists no other less restrictive alternative mechanism for decision-
making.
3. That based on the incapacity of CONSTANCE M. MEREDITH to receive and
evaluate information and to make or communicate decisions, a plenary Guardian of the Person and
plenary Guardian of the Estate are required on a permanent basis.
NOW, THEREFORE, based on the clear and convincing evidence supporting the foregoing
findings it is ORDERED, ADJUDGED and DECREED that CONSTANCE M. MEREDITH be
and is hereby adjudged an incapacitated person, and WILLIAM J. MEREDITH is appointed Plenary
Permanent Guardian of the Person and Estate of CONSTANCE M. MEREDITH. As Plenary
Permanent Guardian of the person, WILLIAM J. MEREDITH has the authority to access all
CONSTANCE M. MEREDITH's medical records, including but not limited to psychiatric .records.
Further, as Guardian of the person, WILLIAM J. MEREDITH shall have the power and authority to
serve as personal representative for all purposes of the Health Insurance Portability and
Accountability Act of 1996, (Pub.L.l 04-191), 45 CFR Sections 160 through 164 ("HIP AA"). The
Guardian shall be considered the personal representative for CONSTANCE M. MEREDITH's heath
care disclosures under the federal HIP AA regulations and shall have full authority to review
CONSTANCE M. MEREDITH's medical records and to execute releases of confidential
information from medical providers and insurers or other third party payors.
As Guardian of the Estate, WILLIAM J. MEREDITH shall have the authority to make
distributions from principal for the payment of care expenses, and all medical needs. In addition,
WILLIAM J. MEREDITH shall have the authority to make distributions from principal for legal fees
and the taxes, utilities, and insurance for any real property owned by CONSTANCE M.
MEREDITH.
An Inventory must be filed within ninety (90) days. A report by the Guardian shall be filed
within 12 months and annually thereafter.
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Bond in the ftfB8W1t of
shall be posted- by the GuardIan.
CONSTANCE M. MEREDITH, an incapacitated person, has the right to appeal this Order of
Court by filing exceptions within ten (10) days of this date or to petition this Court for a review
hearing to modify or terminate the guardianship herein established.
If CONSTANCE M. MEREDITH was not present at this hearing on appointment of
Guardian, then Petitioner shall serve upon and read to CONSTANCE M. MEREDITH the Statement
of Rights, a copy of which is attached to this Order as Exhibit "A", and file proof of such service
with this Court within ten days.
BY THE COURT:
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A TRUE COpy FROM RECORD
In Testimony wherof, I hereunto
set my hand and the seal
of said Court at Carlisle, PA
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AttMrh ~~U,Lu:
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Cumbel1and County.. . (
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IN RE: CONSTANCE M. MEREDITH : IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYL VANIA
: ORPHANS' COURT DMSION
An alleged incapacitated person : NO. 06~0294
On the Petition of WILLIAM J. MEREDITH
STATEMENT OF RIGHTS UPON APPOINTMENT OF A GUARDIAN
AN ORDER HAS BEEN ENTERED WHEREBY YOU HA VE BEEN ADJUDICATED AN
INCAPACITATED PERSON AND UNABLE TO CARE FOR YOURSELF AND/OR MANAGE
YOUR PERSONAL AFFAIRS. YOU HAVE THE RIGHT TO FILE EXCEPTIONS TO THE
COURT'S DECISION WITHIN TEN (10) DAYS OF THE DATE OF THE COURT'S ORDER. IF
YOU FAIL TO FILE EXCEPTIONS, THE ORDER WILL BECOME FINAL. IN THE EVENT
THA T YOU FILE EXCEPTIONS AND THEY ARE DENIED, YOU HAVE A RIGHT TO FILE
AN APPEAL TO THE SUPERIOR COURT WITHIN THIRTY (30) DAYS OF THE DATE OF
THE DENIAL OF THE EXCEPTIONS.
IN ADDITION, YOU MAY PETITION THE COURT AT ANY FUTURE TIME TO
MODIFY OR TO TERMINATE THE GUARDIANSHIP IF THERE IS A CHANGE IN YOUR
CAPACITY OR IF YOUR GUARDIAN FAILS TO PERFORM HIS/HER DUTIES IN
ACCORDANCE WITH THE COURT'S ORDER.
IF YOU WISH TO APPEAL THE ORDER OR TO PETITION THE COURT TO MODIFY
OR TERMINATE THE GUARDIANSHIP, YOU HA VE THE RIGHT TO BE REPRESENTED BY
AN ATTORNEY. IF YOU DO NOT HAVE AN ATTORNEY, THE COURT MAY APPOINT
ONE TO REPRESENT YOU. IF YOU CANNOT AFFORD AN ATTORNEY, THE SERVICES
OF AN ATTORNEY WHOM THE COURT MAY APPOINT FOR YOU MAYBE PROVIDED
AT NO COST TO YOU.
Exhibit "A"
,055 Pa. Code ~ 178.104. Disposition of assets and fair consideration provisions for transf... Page 1 of 4
~ 178.104. Disposition of assets and fair consideration provisions for transfers on or
after July 30, 1994.
(a) If assets are disposed of on or after July 30, 1994, ~ ~ 178.105 and 178.106 (relating to
presumption of disposition of assets to qualify for MA for transfers on or after July 30,
1994; and reestablishment ofMA eligibility after transfers made on or after July 30, 1994)
and this section apply to an institutionalized individual who is applying for or receiving MA
for NFC as defined in ~ 178.2 (relating to definitions), including services in an ICF/MR, or
a level of care in an institution equivalent to NFC, or home or community-based services
furnished under a Title XIX waiver and the individual or the individual's spouse transfers
assets for less than FMV.
(b) An institutionalized individual who disposes of assets for less than FMV on or after the
look back date in subsection (c) is ineligible for MA for NFC which includes the services
set forth in subsection (a). A transfer of assets by the community spouse to a person other
than the institutionalized spouse is treated and affects the eligibility of the institutionalized
spouse the same as a transfer by the institutionalized spouse.
(c) The look-back date shall be 36 months from the date on which the individual is both
institutionalized and has applied for MA, except in the case of payments from a trust, or
portions of a trust, as described in ~ 178.7(e)(1)(iii) and (2)(ii) (relating to treatment of trust
amounts for all categories of MA for trusts established on or after July 30, 1994) which are
considered assets disposed of for less than FMV by the individual. In this instance, the look-
back date shall be 60 months.
(d) The number of months of ineligibility for the institutionalized individual who disposes
of assets for less than FMV shall be equal to the total cumulative UV of all assets
transferred by the individual or the individual's spouse on or after the look-back date
divided by the average monthly cost to a private patient ofNFC in effect in the
Commonwealth at the time of application.
(e) An individual will not be ineligible for payment for NFC if:
(1) The assets were the resident property and title to the home was transferred to:
(i) The spouse of the individual.
(ii) The individual's child who is under 21 years of age, or blind or permanently and
totally disabled as determined under ~ 140.81 (relating to deductions from earned income),
or is blind or disabled based on SSI criteria as specified in 42 U.S.C.A. S 1382c(a)(3).
(iii) A sibling of the individual who has an equity interest in the home and who resided
in the individual's home for at least 1 year immediately before the date the individual
became an institutionalized individual.
(iv) A son or daughter of the individual, other than a child described in subparagraph
Exhibit "B"
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.055 Pa. Code ~ 178.104. Disposition of assets and fair consideration provisions for transf... Page 2 of 4
(ii), who resided in the individual's home for at least 2 years immediately before the date
the individual became an institutionalized individual and who provided care to the
individual which permitted the individual to reside at home rather than in an institution or
facility .
(2) The assets were transferred to one of the following:
(i) The individual's spouse or to another for the sole benefit of the individual's spouse.
(ii) To another for the sole benefit of the individual's spouse, from the individual's
spouse.
(iii) The individual's child described in paragraph (1 )(ii), or to a trust, including one
described in ~ 178.7(f), established solely for the benefit of the individual's child.
(iv) A trust, including a trust described in ~ 178.7(f), established solely for the benefit
of an individual under 65 years of age who is disabled based on SSI criteria as specified in
42 U.S.C.A. ~ 1382c(a)(3).
(3) The individual, the individual's spouse or someone else acting on behalf of the
individual can show that one of the following applies:
(i) The individual intended to dispose of the assets either at FMV or for other valuable
consideration.
(ii) The assets were transferred exclusively for a purpose other than to qualify for MA.
(iii) The assets transferred for less than FMV were returned to the individual.
(4) The Commonwealth determines that denial of eligibility would cause undue hardship
as defined in 9 178.2.
(f) If an asset is held by an individual in common with other persons in joint tenancy,
tenancy in common or a similar arrangement, the asset or the affected portion of the asset
shall be considered to be transferred by the individual when an action is taken, either by the
individual or by another person, that reduces or eliminates the individual's ownership or
control of the asset.
(g) If a transfer by the individual's spouse results in a period of ineligibility for MA, the
Commonwealth will apportion the period of ineligibility or any portion of the period
between the individual and the individual's spouse if the spouse otherwise becomes eligible
for MA for NFC.
(h) During the period of ineligibility for MA payment for NFC, the nursing facility or
other provider may charge the private pay rate.
Authority
The provisions of this 9 178.104 issued under sections 201(2) and 403(b) of the Public
Welfare Code (62 P. S. 9 9 201(2) and 403(b)).
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,055 Pa. Code S 178.104. Disposition of assets and fair consideration provisions for transf... Page 3 of 4
Source
The provisions of this S 178.104 adopted December 23, 1994, effective December 24,
1994, and apply retroactively to July 30, 1994,24 Pa.B. 6423.
Notes of Decisions
Burden of Proof
This regulation squarely places the burden on the applicant to establish that he or she
"intended" to dispose of the assets for fair market value or for other valuable
consideration, or that the assets were transferred "exclusively" for a purpose other than to
qualify for Medical Assistance. Ptashkin v. Department of Public Welfare, 731 A.2d 238
(Pa. Cmwlth. 1999).
Disposition of Assets
The Department did not misapply the exception regarding disposition of assets; since at
the time of the transfer the applicant and his spouse suffered ailments that could eventually
render them in need of nursing home care, and when the only explanation for the transfer of
real property to children for $1.00 was to keep the property in the family, the Department
determined that the petitioner had failed to satisfy his burden to show that the transfer was
made for a purpose other than to qualify for Medical Assistance. Godown v. Department of
Public Welfare, 813 A.2d 954 CPa. Cmwlth. 2002).
Where a couple converts otherwise countable assets into an irrevocable, actuarially sound
commercial annuity for the sole benefit of the community spouse, the annuity is not a
countable resource in calculating the CSRA. The transfer may not be used to impose a
period of ineligibility. Mertz v. Houston, 155 F. Supp. 2d 415 (E.D. Pa. 2001).
Husband's use of funds transferred from his wife, who is a nursing home resident, to
purchase an annuity from an irrevocable trust established by the couple's adult daughters
was not a permissible spending down of the couple's money, where the purchase of the
annuity was for less than fair consideration, was made with the intent to qualify the wife for
Medical Assistance, and was contrary to the provisions and intent of the Medicare
Catastrophic Coverage Act. Bird v. Department of Public Welfare, 731 A.2d 660 (Pa.
Cmwlth. 1999).
Fair Consideration
The applicant failed to carry her burden of proving her eligibility for Medical Assistance
by showing that the disputed funds were transferred for fair market value or exclusively for
a purpose other than to qualify for Medical Assistance, where the applicant presented
absolutely no evidence other than the promissory notes themselves, and where the
Department of Public Welfare presented evidence that it had discovered that the applicant
had sold her home and received net proceeds of $28,815, but that she, instead of applying
these funds for her nursing home care, transferred them to her adult children in exchange for
two promissory notes, and that she is only receiving $48 per month for 9 years until she
receives the principal, plus accrued interest, in a lump sum due past her life expectancy.
Ptashkin v. Department of Public Welfare, 731 A.2d 238 CPa. Cmwlth. 1999).
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055 Pa. Code ~ 178.104. Disposition of assets and fair consideration provisions for transf... Page 4 of 4
Husband's use of money transferred from his wife, who is a nursing home resident, to
purchase an annuity for $143,000 that would, over a period of 6 years, should he live that
long, reap a return of$144,000, or $600 in interest, but if he died before reaching the end of
his purported life expectancy, his estate forfeits any further return on his investment, was
not for fair consideration. Bird v. Department of Public Welfare, 731 A.2d 660 (Pa.
Cmwlth. 1999).
Multiple Transfers
Where a Medicaid applicant made three consecutive transfers of $9,000 each, the
Department of Public Welfare correctly calculated the period of ineligibility by considering
the total of the cumulative uncompensated value of the transferred assets instead of viewing
each transfer separately. Heffilfinger v. Department of Public Welfare, 789 A.2d 349 (Pa.
Cmwlth.2001).
Cross References
This section cited in 55 Pa. Code ~ 178.5 (relating to treatment of irrevocable burial
reserves for all categories ofMA); 55 Pa. Code ~ 178.7 (relating to treatment of trust
amounts for all categories of MA for trusts established on or after July 30, 1994); 55 Pa.
Code ~ 178.105 (relating to presumption of disposition of assets to qualify for MA for
transfers on or after July 30, 1994); 55 Pa. Code ~ 178.106 (relating to reestablishment of
MA eligibility after transfers made on or after July 30, 1994); and 55 Pa. Code ~ 178.175
(relating to presumption of disposition of assets to qualify for MA for transfers on or after
July 30, 1994).
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http://www.pacode.comlsecure/datal055/chapterl78/s178.1 04.html
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CERTIFICATION OF
TRANSPER OF RESOURCES TO
<:.~:.:;-"" COMMUNITY SPOUSE
CASe 100000ACATlON
co AEaJI) NO. CAT.
0tST.
NM
SECTION 303(a) OF niE MEDICARE CATASTROPHIC COVERAGE ACT P.ROVJOES THAi A PERSON IN A NURSING
FACIUTf NAY TRANSFER CERTAIN RESOURCES. SUBJECT TO A MAXIMUM uurr SPECFIEO 1N THE ACT. TO A
SPOUSE LMNG AT HOUE.
I HERESY CERTFY THAT J WIlJ. TRANSFeR RESOURCt:S OWNED BY UE TO MY SPOUSE WITHIN NINETY' (gO)
DAYS FROM 1M! DATE B8.0W.
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I UNDERSTAND THAT A TRANSFER OF RESOURCes. WrrHlN SPECIFIED I.IMITS ESTABL.ISHED BY FEDERAL L.-.W.
TO MY SPaJSE UVING AT HOME Will. NOT AFfECT MY ELIGIBIUN FOA MEDICAL ASSISTANCE (MA) BENEFITS
FOR NURSING CARE.
wrrnESS
PERSON IN NURSING FACILITY/REPRESENTATIVE
MAIlE- l'UASE PAINT)
MoUE (Pl.E.ASE ~M)
$lGlU'ME
a,.,,," Cfl ~SZ:WATM: ~Ar.;JE
DATE
tu.TE
11iE SIGNATURES AND AOORESSES OF TWO WrrNESSES ARE REQUIRED. IF: (1) llotE PERSON IN THE NURSING
FACtllTY SlGNEO WITH AN (Xj. OR (2) A REPRESENTATIVE SIGNED FOR THE PeRSON IN ~e NURSING FACIU'N.
HAM! ,uASE flMlI'rl NAIIE (P\..EA:lE ,..NT1
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IF THIS CERTlFtCATJON IS SIGNED BY A REPRESENTATlVE O~ THE PERSON IN THE NURSING FACILITY, lHE I
REPRESEKTA1WE MUST GIVE HIS ADDRESS. Hrs RElATIONSHIP TO lliE PERSON rN THE NURSING FACILITY.
AND THE REASON THE P~ON IN THE NURSING FACtUTV OlD NOT SIGN.
~A~ ACCRESS
RELJ.'TlC:N5i'
N:ASON
440 APPENDIX E - 1
Exhibit "e"