Missouri’s Medicaid Recovery Claim Based Solely on Computerized Records Is Denied

Missouri’s claim for reimbursement of Medicaid benefits from the estate of a deceased Medicaid recipient was denied because government computerized records were deemed insufficient evidence to assert the claim.

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In the Estate of Strayer v. State (Mo. Ct. App., No. WD 72707, April 19, 2011).

Facts.  Ms. Joanna Strayer qualified for and received Medicaid benefits from the state of Missouri until her death in 2005.  Upon her death, the state filed a claim against her estate in order to seek reimbursement of $52,931.33 in benefits that were supposedly paid to Ms. Strayer during her lifetime.  At the claim hearing, the state submitted ten pages of computerized records as evidence of the benefit amounts paid to Ms. Strayer during her lifetime.

In response to the presentment of the computerized evidence, the representative for the Estate of Joanna Strayer objected and argued that the court should deny the claim against the Estate since the state had not met its burden of proof for recovery of the funds.  The court denied the claim by the state, determining that the computerized records alone were insufficient to support the claim because, although they included cash amounts, they did not indicate that amounts listed represented benefits actually paid to Ms. Strayer.  The court further held that it was “left to speculate as to what the random numbers set forth in the bare records represent[ed].” The state appealed.

Court’s Decision.  The Missouri Court of Appeals, Western District, affirmed the court’s holding to deny the claim for reimbursement, holding that “[t]he State’s computerized records without testimony as to the meaning of the data contained therein or other evidence certifying that payment was made on [Ms.] Strayer’s behalf did not constitute competent and substantial evidence of payment.”