Fischer v. State Department of Social & Rehabilitation Services, 271 Kan. 167

Summary

Donald Fischer appealed the denial of Medicaid eligibility based on the Kansas Department of Social and Rehabilitation Services' classification of farm property and related assets as exempt resources. The Kansas Supreme Court held that the applicants bore the burden of proving that the farmland was not exempt under the applicable regulations, including the requirement that income-producing property generate income consistent with its fair market value. The court affirmed the district court's judgment upholding the agency's determination.

Holdings

1. The Medicaid applicant bears the burden of proving eligibility, including proving that the farmland was not exempt because it failed to produce income consistent with its fair market value.
2. SRS properly classified the Fischers' farm operation as an exempt resource and correctly determined that Donald Fischer was not eligible for Medicaid assistance.

Questions Presented

1. Which party bore the burden of producing evidence concerning whether the farm property produced income consistent with its fair market value and therefore qualified as exempt property under the Medicaid regulations?
2. Whether SRS properly classified the Fischers' farm property and personal property as exempt resources and correctly determined that Donald Fischer was ineligible for Medicaid assistance.

Disposition

affirmed