State, Department of Health & Social Services, Division of Public Assistance v. Gross

Summary

The Alaska Supreme Court reviewed the Department of Health and Social Services’ denial of interim assistance to an applicant for federal Supplemental Security Income benefits. The court held that Alaska law does not require the Department to replicate every procedural aspect of the federal five-step disability analysis, but the Department may not categorically exclude applicants who could qualify for federal benefits at step five. The court affirmed in part, reversed in part, and remanded for further proceedings.

Holdings

1. The substitution-of-judgment standard applies because the issue is statutory interpretation concerning legislative intent, not a policy or technical question within the Department's specialized expertise.
2. AS 47.25.455 does not require the Department to exactly replicate every substantive and procedural aspect of the federal five-step SSI eligibility analysis when determining interim-assistance eligibility.
3. The Department may not interpret 7 AAC 40.180 to exclude from interim-assistance eligibility the entire category of applicants who are entitled to federal SSI benefits only because of the federal step-five determination.

Questions Presented

1. What standard of review applies to the Department's interpretation of the statute governing Alaska interim assistance eligibility?
2. Does AS 47.25.455 require the Department to replicate every substantive and procedural aspect of the federal five-step SSI disability analysis?
3. Is the Department's interpretation of 7 AAC 40.180, which excludes applicants who would qualify for SSI only at step five, consistent with AS 47.25.455?

Disposition

reversed_and_remanded