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Compact to Solve New York's Long Term Care Crisis
By: Vincent J. Russo Esq. and Howard S. Krooks Esq.
An Overview of the Crisis
Anyone
who has ever encountered the issue of financing Long Term
Care thoroughly comprehends the adversarial nature and needlessly
complicated process of applying for Medicaid. Indeed, our
current Long Term Care system is in desperate need of reform.
Paying for Long Term Care is the single greatest hurdle faced
by seniors today who are concerned about planning a future
that secures their assets and preserves their dignity. Unequivocally,
confronting this problem is of the utmost exigency since Medicaid
is the only government assistance program that subsidizes
Long Term Care, a vital service to countless seniors and members
of our society who are disabled.
Long Term
Care is essentially custodial in nature and as such, assists
chronically disabled individuals with their daily activities
of living over a prolonged period as they compensate for their
loss of the physical and/or mental ability to function independently.
Providing assistance with activities of daily life, such as
eating, toileting, transferring, bathing, dressing and continence,
is the primary function of Long Term Care. Long Term Care
is necessary for many seniors and persons with disabilities,
but it is also expensive. Medicaid is the most common government
program to which seniors and people with disabilities turn
to. Other options, including private payment and Long Term
Care insurance, are often too costly or exclusive. Medicaid
covered just under 50% of national spending on nursing home
care in 2003 while in stark contrast private insurance covered
less than 10%, evidence that Medicaid is essential for seniors
and people with disabilities for their Long Term Care needs.
However, the primary prerequisite of the current system is
an impoverishment process that undermines the American dream.
The reality is that most seniors and people with disabilities
cannot afford to pay for Long Term Care indefinitely but possess
some assets in excess of the stringent Medicaid eligibility
limits. Many find themselves in health-care limbo since Medicare
does not cover Long Term Care services. This puts seniors
and individuals with disabilities in an untenable position
with no readily available system to which they can turn. Most
people agree that it is inappropriate for American citizens
to be impoverished to pay for Long Term Care. As a last resort,
people who lack private pay funds and/or do not have coverage
under a Long Term Care policy turn to Medicaid. So far, no
other alternatives have emerged.
The New
York State Bar Association Elder Law Section's Long Term Care
Reform Committee has proposed an alternative method of financing
Long Term Care in a way that seeks to help New York State
residents access the Long Term Care they need while at the
same time curbing the burgeoning costs of the Medicaid Program.
This proposal, entitled the Compact, brings a new approach
to determining an applicant’s eligibility for government-subsidized
Long Term Care services. The idea stems from Gail Holubinka,
the primary designer and first director of the NYS Partnership
for Long Term Care. Ms. Holubinka provided the initial concept
that evolved into the Compact proposal. The Compact Working
Group, a subcommittee of the Long Term Care Reform Committee,
has devised a novel plan that is both realistic and pragmatic.
This summary
of the New York State Long Term Care Compact reflects the
views of its authors and is neither endorsed nor rejected
by the New York State Bar Association and its Elder Law Section.
The Compact proposal is a work in progress. The Compact proposal
reflects the continuing painstaking efforts of the Compact
Working Group, whose members include Michael Amoruso, Esq.,
Howard Angione, Esq., Daniel G. Fish, Esq., Gail Holubinka,
Howard S. Krooks, Esq., Louis W. Pierro, Esq., and Vincent
J. Russo, Esq. This article reflects only the views of the
authors, who currently serve as co-chairs of the Compact Working
Group.
The
Fundamental Design of the Compact
The cornerstone
of the Long Term Care Compact is to create a partnership between
seniors and people with disabilities and government wherein
seniors and people with disabilities will pay a fair share
for Long Term Care services with the government’s support.
The foundation of the program is the belief that public policy
concerning social programs should be a contract between seniors
and people with disabilities and the government. Under the
contract, the senior or the person with a disability pledges
to contribute his/her fair share of the cost burden of Long
Term Care services in exchange for retaining a protected amount
of personal assets while receiving government assistance.
Under
the current Medicaid system, poverty status is required before
one can obtain government assistance to pay for Long Term
Care. As a result, most seniors and people with disabilities
in need of Long Term Care face the Hobson’s choice:
spend down the modest estate they have struggled to earn over
a lifetime or transfer their assets to children or other relatives
voluntarily imposing impoverishment on themselves. However,
these transfers result in harsh penalties against the applicant
resulting in a period of refused government assistance in
accordance with transfer penalty rules. In fact, there is
a movement among several states, and even in the United States
Congress, to increase the penalties and so-called “look
back periods” as a way to solve the Medicaid crisis.
What kind of solution is that? Penalties and look back periods
leave applicants both destitute and devoid of assistance,
worse off then when they began the process. We, as a society,
can and must do better.
The Compact
would rectify this quagmire, utilizing a rather simple approach.
Briefly, once individuals receive a chronically ill diagnosis,
instead of frantically giving away their assets to qualify
for Medicaid assistance, they pledge to use a defined amount
of their existing assets to pay for their Long Term Care needs.
Until this pledged amount is spent, they remain responsible
for their own care needs, independent of Medicaid, while retaining
full access to the aggregate of their income and assets. Once
they have spent the pledged amount, applicants then retain
their private pay status but become eligible for the Compact
Subsidy to pay for approximately 90% of their Long Term Care
costs. At this point, participants would pay 25% of their
monthly countable income to the government’s administering
agency, using the remaining 75% to pay the portion of their
Long Term Care expenses not covered by the Compact Subsidy
as well as any ancillary medical expenses.
Under
the Compact program, Medicaid becomes the true safety net
it was intended to be when it became law in 1965. This Compact
proposal would relieve the ever-burgeoning financial stress
placed upon the Medicaid system while at the same time empowering
individuals to preserve their dignity and quality of life.
In developing the Compact proposal, the Compact Working Group
members have considered diverse interest groups (i.e., the
legislative and executive branches, the insurance industry,
the consumer, the health care provider, and the Department
of Health) and thought through the vast landscape of many
issues impacted by the implementation of such a proposal.
Furthermore, the Compact proposal’s political bi-partisan
appeal is encouraging. The concept of privatization and decreased
government spending should appeal to Republicans. The extension
of government benefits the proposal will spawn should appeal
to Democrats. The Compact proposal has the kind of bi-partisan
appeal that will be instrumental to the achievement of a sweeping
change. Above all, the Compact is a common sense approach
to our health-care crisis, a growing crisis that looms ever
nearer as we charge full speed toward the retirement of the
baby-boom generation and the continued aging of the American
populace.
At the
time of this printing, New York State Senator Martin J. Golden,
chair of the Senate Aging Committee, has sponsored legislation
to implement the New York Compact for Long Term Care. The
foundation of S.3530, the Bill's title, lies in the same principles
outlined herein. We anticipate re-introduction of the Bill
with revisions in the next legislative session of the New
York State Senate.
An
In-Depth Analysis of the Compact
The Compact
concept raises a plethora of questions and issues; therefore,
we shall address what we consider the most salient points
of the Compact proposal. The Compact would work within the
established infrastructure of the current Medicaid program
and would serve as an alternative to facilitate a less complicated
process, eventually reducing the administrative burdens and
costs necessary to operate the program.
The Compact
consists of two basic phases: 1) the Pledge period, during
which time the applicant is referred to as an Eligible Individual,
and 2) the Compact Subsidy period, during which time the applicant
is referred to as a Compact Participant. We will discuss the
highlights of each of the two phases throughout the remainder
of this article.
Phase
I: The Pledge
Pledge
Amount: The pledge amount is the lesser of the regional
rate calculated for three years (36 months), known as the
Maximum Pledge Amount, or one-half the value of the Eligible
Individual's countable assets on the Compact Pledge Date (as
defined herein), known as the Dollar Pledge Amount. For example,
in New York City the 2005 Regional Rate is$8,870, hence the
maximum pledge amount for a New York City Eligible Individual
would be $319,320.
An Eligible
Individual will have the freedom to elect, at his or her option,
the Maximum Pledge Amount even if the Dollar Pledge Amount
is lower. The remaining assets not pledged are referred to
as the Protected Amount. A Compact Participant will not be
required to spend down for Long Term Care services any assets
designated as a Protected Amount.
If an
Eligible Individual has less than $40,000 in countable assets,
the Dollar Pledge Amount is limited to the amount in excess
of $20,000, with both figures subject to annual adjustment
for inflation. Once the Pledge Amount has been spent for qualified
Long Term Care services, the Eligible Individual has satisfied
his or her obligation under the Compact. At this point, the
Eligible Individual enters the second phase of the Compact,
which provides assistance equal to the Compact Subsidy Amount
(discussed later in this article).
Compact
Pledge Date: The Compact Pledge Date is the date
upon which the Eligible Individual has satisfied the two requirements
to enter into the Compact program contract: 1) the individual
qualifies for Long Term Care services, and 2) the government’s
third party administrator has made a determination of the
Pledge Amount and the individual has agreed to the Pledge
Amount.
Countable
Assets: Unless specifically exempted by the Compact
rules, countable assets will continue to include all those
defined in 366 of the New York State Social Services Law,
the current Medicaid law in New York.
Homestead
Exemption: For purposes of calculating countable
assets, a Homestead is exempt regardless of value and regardless
of whether the Maximum Pledge or Dollar Pledge Amount is applicable,
unless the Homestead was purchased within three years of the
Compact Pledge Date. In such event, the Homestead value would
be included when computing countable assets unless the Homestead
replaces a Homestead sold within a one-year period. If a replacement
Homestead was purchased within one year, then countable assets
would only include an amount equal to the difference between
the gross sale price of the prior Homestead and the net purchase
price of the new Homestead.
Look
Back Rules: An attractive feature of the Compact’s
Maximum Pledge Amount is the elimination of the look back
period often associated with the Medicaid program. Under the
Compact program, when the Maximum Pledge Amount is pledged,
there is no look back period, penalty period, or review of
financial documentation, making the program friendly for both
the user and the administrator. Only when the Dollar Pledge
Amount is pledged would a three year look back period apply,
pursuant to which the Eligible Individual would disclose and
certify, subject to penalties for perjury, a list of current
assets, their values and any asset transfers for less than
full consideration within the past three years. Income tax
returns, if filed, would constitute the only documents required
to be submitted although the government’s third party
administrator could request further documentation to verify
assets (and values) as well as the amount of any uncompensated
assets transferred. While there would be no penalty period
established for asset transfers made within the three-year
look back period, under the Compact program, any asset transfers
made within three years of the Compact Pledge Date would be
added back to the sum of countable assets used for the purposes
of determining the Pledge Amount.
Spousal
Rules: A married couple must disclose total assets
without distinction as to who owns the assets. Likewise, agreements
between husband and wife regarding asset ownership contained
in any pre-nuptial or post-nuptial agreement, executed less
than three years before the Compact Pledge Date would not
be recognized. For the first spouse requiring qualified Long
Term Care services, the Pledge Amount would be the lesser
of the Maximum Pledge Amount or one fourth of the couple's
countable assets (constituting the Dollar Pledge Amount),.
Assets of a non-pledging spouse who has entered into a pre-nuptial
or post-nuptial agreement made more than three years prior
to the Compact Pledge Date are not considered “countable
assets” and would not have to be disclosed under the
Compact rules.
If the
Maximum Pledge Amount applies, then the Protected Amount would
be equal to one-half the couple's countable assets minus the
Maximum Pledge Amount. If the Dollar Pledge Amount applies,
then one-fourth of the couple's countable assets would constitute
the Protected Amount. If the other spouse requires qualified
Long Term Care services, the Pledge Amount calculation is
different. In that case the Pledge Amount of the second spouse
would be the lesser of the Maximum Pledge Amount or one half
of the couple's remaining countable assets after subtracting
the first spouse's Protected Amount and, if the first spouse
has not completed his or her pledge, the amount needed to
complete the first spouse’s pledge.
On the
death of the first spouse, if the Protected Amount passes
to the surviving spouse, it is not included in computing the
surviving spouse’s countable assets when applying for
Compact coverage. Furthermore, if maintained in a segregated
account the growth and income of the Protected Amount are
also protected. The surviving spouse of a Compact Participant
is not required to exercise a right of election under ' 5-1.1-A
of the Estates Powers and Trusts Law if the Will of the first
spouse leaves the Protected Amount to someone other than the
surviving spouse.
Advisory
Committee: Senate Bill S. 3530 , as introduced on
March 21, 2005 to the New York State Senate, is the first
attempt to codify the Compact proposal. The Bill provides
a system for the creation of an Advisory Committee to address
the many concerns expected to arise through implementation
of the Compact program (especially pertaining to the unpredictable
nature of the issues that could arise in the spousal context).
The main purpose of the Advisory Committee is to provide for
the continued development of the Compact program once implemented.
The proposed Committee would be comprised of seven appointees.
Individuals on the Advisory Committee would operate under
the auspices of the Compact Program Commissioner and would
receive no compensation for their work besides that which
covers the expenses of their duties.
Estate
Recovery: Once the Maximum Pledge or the required
Dollar Pledge Amount has been satisfied, there will be no
estate recovery of any Protected Amount or the Homestead.
Annuities:
The Compact program has three basic rules concerning the treatment
of annuities in the Pledge process:
1) Annuities
Purchased Within Three Years of Compact Pledge Date
– An annuity in permanent payout status purchased
within three — years of the Pledge Date is a countable
asset for Pledge purposes. However, payout amounts are not
treated as ccountable income later on in the Compact process
when the Eligible Individual has satisfied the Pledge Amount
and becomes a Compact Participant, eligible for Compact
Subsidy payments.
2)
Annuities Purchased Prior To Three Years of Compact Pledge
Date — In contrast, an annuity is not a countable
asset if a level payment schedule has been in force for
three or more years before the Compact Pledge Date. However,
payout amounts are treated as “countable income”
later on in the Compact process when the Eligible Individual
has satisfied the Pledge Amount and becomes a Compact Participant,
eligible for Compact Subsidy payments. The monthly amount
of a level payment schedule would be based on the value
of the assets invested, the anticipated interest, and the
person's life expectancy as established by the Internal
Revenue Code and the applicable Treasury Regulations promulgated
thereunder.
3) Annuities Not in Permanent Payout Status —
Annuities that are not in a permanently established payout
status for three-years prior to the Compact Pledge Date
are treated as countable assets for the purposes of calculating
an Eligible Individual's Pledge Amount.
Irrevocable
Trusts: The value of any asset placed in an Irrevocable
Trust for less than full consideration within the three-year
look back period prior to the Compact Pledge Date would be
included in the computation of countable assets to determine
whether a Maximum Pledge Amount or Dollar Pledge Amount is
applicable.
Pre-Plan
Funerals: A Pre-Plan funeral purchased by an Eligible
Individual for him or herself, a spouse, or children with
disabilities, would not be included in the computation of
countable assets if purchased before fulfillment of the Compact
Pledge. A Pre-Plan funeral purchased after the Compact Pledge
Date but before the Compact Pledge has been fulfilled, results
in the downward adjustment of the Compact Pledge Amount to
account for the expense.
Debts:
All debts, including but not limited to outstanding amounts
on credit cards, auto payments, mortgages, home equity loans,
reverse mortgages, and the like, would be deducted from the
countable assets for purposes of determining the applicable
Pledge Amount.
Long
Term Care Savings Account (LTCSA): Individuals who
applied for Long Term Care Insurance, and were denied coverage
due to the underwriting process would have the option, under
the Compact program, to place a defined amount of money in
a Long Term Care Savings Account (LTCSA) each year. The proposed
computation of the maximum annual deposit amount is a sum
not to exceed twice the current annual IRA contribution limit
(which is presently $4,000) allowed under the Internal Revenue
Code and applicable U.S. Treasury Regulations. Amounts placed
in the LTCSA annually would be eligible for the same tax deductions
available to those who contribute to an IRA account. In addition,
the amount in the LTCSA would not count when computing that
individual's countable assets. There would be no federal or
state income tax consequences for the expenditure of funds
from the LTCSA to fulfill the Pledge Amount.
When
the need for care arises and an Eligible Individual makes
a Compact Pledge, LTCSA funds are the first assets expended
to meet the Pledge Amount. If funds placed into the LTCSA
are insufficient to fulfill the Pledge, the Eligible Individual
would be required to use a portion of his/her unprotected
countable assets. If any funds remain within the unprotected
countable assets upon completion of the Compact Pledge, those
funds would be added to the Protected Amount as the Eligible
Individual entered Phase Two of the Compact Program (becoming
a Compact Participant, eligible for Compact Subsidy payments).
If a LTCSA holder dies without using some or even all of the
funds placed into the account, the remaining balance would
be payable to the state without any federal or state income
or estate tax consequences.
Asset
Management During Pledge Amount Spend Down: Individuals who
have made Pledges will have the option of placing funds sufficient
to fulfill their Compact Pledge into segregated set-aside
accounts comparable to those established to assure Medicare's
reimbursement in workers' compensation cases. This is the
same principle established in New York State Partnership for
Long Term Care Policies. Compact participants may make uncompensated
transfers from the Protected Amount (the amount remaining
after the Pledge Amount is satisfied), although they will
be responsible for assuring that their total assets do not
fall below the amount needed to fulfill a Compact Pledge.
Inheritance
Received After Pledge Amount Is Determined: If a
Compact Participant receives an inheritance after the Pledge
Amount has been determined and the Compact Pledge Date has
passed, the calculation of countable assets and the Compact
Pledge Amount is not adjusted to reflect the acquisition of
new assets. This is the same principle that applies in New
York State Partnership for Long Term Care Policies. If the
Compact Participant is unmarried, the inherited funds are
added to the Protected Amount. For a married couple, one-half
of the additional funds would be added to the Compact participant’s
Protected Amount and the other half would be considered part
of the Compact spouse’s countable assets should he/she
later apply to participate in the Compact Program. If both
spouses have already fulfilled his/her pledge, then the inheritance
is added to the Protected Amount of each spouse in equal amounts.
Disqualification: Under the proposed New York legislation,
Senate Bill S. 3530 clearly articulates grounds for disqualification
from the Compact Program in a manner that seeks to penalize
with fairness. Eligible Individuals who fail to fulfill their
Compact Pledge have breached the contract. Breaching parties
are denied Compact Program benefits. However, such individuals
would retain the right to apply for Medicaid if eligibility
for that program could otherwise be established. Eligible
Individuals who are found to have engaged in deceptive or
fraudulent practices with respect to fulfilling a Compact
Pledge would be disqualified from the Compact Program. In
such a case, a fulfilled Compact Pledge would not be recognized,
as the individual would no longer be considered eligible to
be a participant in the Compact Program. Senate Bill 3530
states that any individual who knowingly makes a false statement
or representation, or who by deliberate concealment of any
material fact, or by impersonation or other fraudulent device,
obtains or attempts to obtain or aids or abets any person
to obtain coverage under the Compact Program to which such
individual is not entitled shall be guilty of a class A misdemeanor,
unless such act constitutes a violation of a provision of
the penal law of the state of New York, in which case he shall
be punished in accordance with the penalties fixed by such
law.
Phase
II: The Compact Subsidy
Compact
Subsidy: Once an Eligible Individual has fulfilled
his or her Pledge obligations, the government commences its
coverage of qualified Long Term Care services. Compact Subsidy
Amount is the amount of money the government's administering
agency would pay toward covered services provided to the Compact
Participant. This amount is equal to the Medicaid Rate applicable
to individuals receiving standard Medicaid coverage. However,
providers could charge Compact Participants a Compact Rate
which can be up to 110% of the Compact Subsidy Amount. Thus,
the government’s liability for qualified Long Term Care
expenses is limited to the Medicaid rate, yet providers may
charge Participants at the Compact Rate, a figure that is
higher than the Compact Subsidy Amount, but lower than private-pay
rates. The Compact Participant is responsible for making whole
the Co-Pay Amount, which is the difference between the Compact
Rate charged by the provider and the Compact Subsidy Amount
paid by the government.
Treatment
of Income: Once an Eligible Individual has fulfilled
his or her Pledge obligation, the second phase of the Compact
Program, known as the Compact Subsidy period, commences. The
Compact Participant would be required to pay 25% of his/her
Monthly Countable Income to the government's administering
agency for the Compact Program. The remaining 75% of the Compact
Participant's Monthly Countable Income would constitute his/her
Monthly Income Allowance, an amount representing the minimum
monthly income that the Compact Participant could retain.
A portion of this Monthly Income Allowance would be used to
meet the Participant’s Co-Pay obligations (discussed
above in “Compact Subsidy”), subject to a floor
defined as the Minimum Monthly Income Allowance. Co-Pay obligations
would cease at the point where the balance remaining from
the Participant's Countable Income fell below this figure.
Countable
Income: Monthly Countable Income would include those
sources of income identified in ' 366 of the New York State
Social Services Law, the current Medicaid law, excluding Exempt
Income and Income Deductions allowed under the Social Services
Law. For example, Exempt Income would include Agent Orange
payments or Reparation payments while Income Deductions would
include payments for health insurance premiums for Medicare
Supplemental health insurance policies. With respect to annuities,
payments received from a level payment annuity purchased within
three years before the Compact Pledge Date would be treated
as a Countable Asset rather than as Countable Income.
The
Role of Long Term Care Insurance: The Compact Pledge
Amount can be fulfilled in whole or in part with Long Term
Care insurance. While certain individuals cannot afford or
obtain (for medical reasons) Long Term Care insurance, Long
Term Care insurance can still play a vital role in the Compact
program. If a Compact Participant remains eligible for further
Long Term Care insurance payments after fulfillment of the
Compact Pledge, the policy would serve as a “secondary
coverage” for services not paid for by the Compact Subsidy.
Conclusion
The efforts
of the Compact Working Group in developing the New York State
Long Term Care Compact are by no means complete or etched
in stone. However, we hope that the summary of the program
as contained in this article will foster a better understanding
of the Compact Program and that this article will serve as
a model for other states trying to deal with the burgeoning
costs of their Medicaid programs. The authors are committed
to continuing their exploration of the Compact proposal. The
authors will produce a future article with examples of how
the Compact proposal would work in common real-life situations.
The bottom line is that the time has come to take a bold step
toward reform; the cost of doing nothing to help America’s
seniors and persons with disabilities is simply too great.
Long Term Care is vital and our most vulnerable citizens should
not have to impoverish themselves to obtain needed services.
America’s senior citizens have consistently made contributions
to our society, building this country into a world leader;
we owe them a future that holds more than impoverishment and
degradation. We are a nation of can-do people who see a problem
and devise a solution that seeks to address the concerns of
many. The New York State Long Term Care Compact is the result
of that culture. We feel that the Compact, if properly implemented,
would solve many of our Long Term Care problems and, most
importantly, help our seniors and people with disabilities
live in peace and with dignity. We owe this solution not so
much to politicians and legislators, but to our own parents,
friends, and all those who need Long Term Care. The Compact
program is an idea whose time has come. It can work. It is
time we put our energy together to change the system for the
better before we become the very same seniors who find ourselves
in need Long Term Care services with no way to pay. This is
indeed one issue that is not going away.
____________________
1. Brien,
Ellen, Medicaid's coverage of nursing home costs: Asset
shelter for the wealthy or essential safety net? (May
2005) http://ltc.georgetown.edu
2. See herein,
Phase II, The Compact Subsidy.
3. Soc. Serv. Law
§ 366 (5) (c) (4)
4. New York Senate
Bill S. 3530, introduced on March 21, 2005.
5. The Advisory
Committee would be comprised of the following: The Chair of
the Elder Law Section of the New York State Bar Association;
one member of the Elder Law Section of the New York State
Bar Association; two members from statewide advocacy groups
that deal with senior issues; two members with at least five
years experience in the development of Long Term Care insurance
products; and one member with at least five years actuarial
or accounting experience in health insurance matters.
6. Senate Bill
S. 3530, introduced on March 21, 2005.
____
Vincent
J. Russo, J.D., LL.M., CELA, is the Founding Member
and Managing Partner of Vincent J. Russo and Associates, P.C.,
with offices in Westbury, Islandia, Lido Beach, Smithtown,
and Woodbury, New York. He is a Founding Member, Fellow, and
Past President of the National Academy of Elder Law Attorneys
(NAELA), presently the Chair of the NAELA Medicaid Strategies
Task Force, a Founding Member and Past Chair of the Elder
Law Section of the New York State Bar Association (NYSBA),
presently Co-Chair of the Compact Working Group.
Howard
S. Krooks, J.D., CELA, is a partner with Elder Law
Associates, P.A., with offices located in Boca Raton, Aventura,
West Palm Beach, and Weston, Florida. Mr. Krooks also serves
as Of Counsel to Littman Krooks LLP, with offices in New York
City and White Plains, New York. Mr. Krooks is the Immediate
Past Chair of the Elder Law Section of the New York State
Bar Association, where he formerly served as Chair of the
Medicaid Committee, and where he presently serves as Co-Chair
of the Compact Working Group.
The authors wish to acknowledge the efforts of the following
individuals, all of whom serve as members of the New York
State Bar Association Elder Law Section Compact Working Group
and who have worked tirelessly to develop the Compact proposal:
Michael Amoruso, Esq., Howard Angione, Esq., Daniel G. Fish,
Esq., Gail Holubinka, and Louis W. Pierro, Esq.
The
authors also wish to recognize and thank Robert Russo for
his significant effort and contribution to the writing of
this article. |
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