{ "id": 3615094, "name": "ROBERT N. POINDEXTER et al., Appellants, v. THE STATE OF ILLINOIS, Acting Through the Department of Human Services, et al., Appellees", "name_abbreviation": "Poindexter v. State", "decision_date": "2008-04-03", "docket_number": "No. 104853", "first_page": "194", "last_page": "217", "citations": [ { "type": "official", "cite": "229 Ill. 2d 194" } ], "court": { "name_abbreviation": "Ill.", "id": 8772, "name": "Illinois Supreme Court" }, "jurisdiction": { "id": 29, "name_long": "Illinois", "name": "Ill." }, "cites_to": [ { "cite": "372 Ill. App. 3d 1021", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 4268871 ], "weight": 9, "pin_cites": [ { "page": "1025" }, { "page": "1025-26" }, { "page": "1029" }, { "page": "1029" }, { "page": "1029-30" }, { "page": "1029" }, { "page": "1036", "parenthetical": "Knecht, J., dissenting" }, { "page": "1029" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/372/1021-01" ] }, { "cite": "42 U.S.C. \u00a71396", "category": "laws:leg_statute", "reporter": "U.S.C.", "pin_cites": [ { "page": "et seq." } ], "opinion_index": 0 }, { "cite": "221 Ill. 2d 222", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5703412 ], "weight": 2, "year": 2006, "pin_cites": [ { "page": "227" }, { "page": "228" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/221/0222-01" ] }, { "cite": "534 U.S. 473", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 9108356 ], "weight": 27, "year": 2002, "pin_cites": [ { "page": "480" }, { "page": "944" }, { "page": "967" }, { "page": "481" }, { "page": "944" }, { "page": "967" }, { "page": "481" }, { "page": "944" }, { "page": "967" }, { "page": "483-84" }, { "page": "946" }, { "page": "969" }, { "page": "480" }, { "page": "944" }, { "page": "967" }, { "page": "479" }, { "page": "944" }, { "page": "967" }, { "page": "480-81" }, { "page": "944" }, { "page": "967" }, { "page": "479-80" }, { "page": "944" }, { "page": "967", "parenthetical": "\"Similarly, assets held jointly by the couple were commonly deemed 'available' in full to the institutionalized spouse\" (emphasis added)" }, { "page": "491" }, { "page": "951" }, { "page": "973" } ], "opinion_index": 0, "case_paths": [ "/us/534/0473-01" ] }, { "cite": "91 F. Supp. 2d 754", "category": "reporters:federal", "reporter": "F. Supp. 2d", "case_ids": [ 6463752 ], "year": 2000, "pin_cites": [ { "page": "761", "parenthetical": "with the MCCA, \"Congress intended to close the loophole where a couple could shelter resources in the community spouse's name while the institutionalized spouse received Medicaid\"" } ], "opinion_index": 0, "case_paths": [ "/f-supp-2d/91/0754-01" ] }, { "cite": "425 Mass. 738", "category": "reporters:state", "reporter": "Mass.", "case_ids": [ 274505 ], "year": 1997, "pin_cites": [ { "page": "740" } ], "opinion_index": 0, "case_paths": [ "/mass/425/0738-01" ] }, { "cite": "682 N.E.2d 874", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1997, "pin_cites": [ { "page": "876" } ], "opinion_index": 0 }, { "cite": "154 N.J. 158", "category": "reporters:state", "reporter": "N.J.", "case_ids": [ 1354440 ], "weight": 2, "year": 1998, "pin_cites": [ { "page": "171" }, { "page": "195" } ], "opinion_index": 0, "case_paths": [ "/nj/154/0158-01" ] }, { "cite": "9 Elder L.J. 27", "category": "journals:journal", "reporter": "Elder L.J.", "year": 2001, "pin_cites": [ { "parenthetical": "noting that the key provisions of the MCCA are the \"deeming\" and \"diversion\" provisions" } ], "opinion_index": 0 }, { "cite": "453 U.S. 34", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 11721956 ], "weight": 6, "year": 1981, "pin_cites": [ { "page": "44" }, { "page": "470" }, { "page": "2640" }, { "page": "44-45" }, { "page": "470" }, { "page": "2640-41" } ], "opinion_index": 0, "case_paths": [ "/us/453/0034-01" ] }, { "cite": "382 F.3d 1162", "category": "reporters:federal", "reporter": "F.3d", "case_ids": [ 2190370 ], "year": 2004, "pin_cites": [ { "page": "1165" } ], "opinion_index": 0, "case_paths": [ "/f3d/382/1162-01" ] }, { "cite": "209 Ill. 2d 520", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5462174 ], "weight": 4, "year": 2004, "pin_cites": [ { "page": "532" }, { "page": "532-33" }, { "page": "533" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/209/0520-01" ] }, { "cite": "227 Ill. 2d 364", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5705969 ], "weight": 2, "year": 2008, "pin_cites": [ { "page": "369" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/227/0364-01" ] }, { "cite": "156 Ill. 2d 112", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 777542 ], "year": 1993, "pin_cites": [ { "page": "116-17" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/156/0112-01" ] }, { "cite": "204 Ill. 2d 363", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 609705 ], "weight": 2, "year": 2003, "pin_cites": [ { "page": "374" }, { "page": "374" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/204/0363-01" ] }, { "cite": "212 Ill. 2d 311", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 2444417 ], "weight": 5, "year": 2004, "pin_cites": [ { "page": "320" }, { "page": "320-21" }, { "page": "320-21" }, { "page": "321" }, { "page": "321", "parenthetical": "\"An aggrieved party may seek judicial review of an administrative decision without complying with the exhaustion of remedies doctrine where a statute *** is attacked as unconstitutional on its face\"" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/212/0311-01" ] }, { "cite": "13 Ill. 2d 493", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 2774874 ], "year": 1958, "pin_cites": [ { "page": "495" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/13/0493-01" ] }, { "cite": "74 Ill. 2d 541", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 2994664 ], "weight": 2, "year": 1978, "pin_cites": [ { "page": "550", "parenthetical": "\"Exhaustion is not required where a statute or rule under which an administrative body purports to act is challenged as unauthorized, since the judicial determination will affect the jurisdiction of the administrative body in all matters, not only in the instant circumstances\"" }, { "page": "550-51" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/74/0541-01" ] }, { "cite": "159 Ill. 2d 381", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 781330 ], "weight": 5, "year": 1994, "pin_cites": [ { "page": "388" }, { "page": "383" }, { "page": "385" }, { "page": "390-91" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/159/0381-01" ] }, { "cite": "68 Ill. 2d 540", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5809328 ], "year": 1977, "pin_cites": [ { "page": "546" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/68/0540-01" ] }, { "cite": "387 U.S. 136", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 11335008 ], "weight": 3, "year": 1967, "pin_cites": [ { "page": "148-49" }, { "page": "691" }, { "page": "1515" } ], "opinion_index": 0, "case_paths": [ "/us/387/0136-01" ] }, { "cite": "227 Ill. 2d 128", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5705656 ], "year": 2007, "opinion_index": 0, "case_paths": [ "/ill-2d/227/0128-01" ] }, { "cite": "223 Ill. 2d 1", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 3605098 ], "year": 2006, "pin_cites": [ { "page": "15", "parenthetical": "\"[wjhether state law is preempted by a federal statute is a question of law, subject to de novo review\"" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/223/0001-01" ] }, { "cite": "227 Ill. 2d 281", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5705625 ], "weight": 2, "year": 2008, "pin_cites": [ { "page": "288" }, { "page": "288" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/227/0281-01" ] }, { "cite": "496 U.S. 72", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 12121785 ], "weight": 3, "year": 1990, "pin_cites": [ { "page": "78-79" }, { "page": "74" }, { "page": "2275" } ], "opinion_index": 0, "case_paths": [ "/us/496/0072-01" ] }, { "cite": "501 U.S. 597", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 1107682 ], "weight": 3, "year": 1991, "pin_cites": [ { "page": "604" }, { "page": "542" }, { "page": "2481" } ], "opinion_index": 0, "case_paths": [ "/us/501/0597-01" ] }, { "cite": "212 Ill. 2d 489", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 2444731 ], "year": 2004, "pin_cites": [ { "page": "517", "parenthetical": "\"A reviewing court is entitled to have issues clearly defined with relevant authority cited\"" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/212/0489-01" ] }, { "cite": "370 Ark. 490", "category": "reporters:state", "reporter": "Ark.", "case_ids": [ 5570075 ], "weight": 2, "year": 2007, "opinion_index": 0, "case_paths": [ "/ark/370/0490-01" ] }, { "cite": "8 N.Y.3d 724", "category": "reporters:state", "reporter": "N.Y.3d", "case_ids": [ 5697727 ], "weight": 3, "year": 2007, "opinion_index": 0, "case_paths": [ "/ny3d/8/0724-01" ] }, { "cite": "956 So. 2d 666", "category": "reporters:state_regional", "reporter": "So. 2d", "case_ids": [ 8315703 ], "year": 2007, "opinion_index": 0, "case_paths": [ "/so2d/956/0666-01" ] }, { "cite": "20 C.F.R. \u00a7416.1205", "category": "laws:admin_compilation", "reporter": "C.F.R.", "year": 2001, "opinion_index": 0 }, { "cite": "226 Ill. 2d 515", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 3610763 ], "year": 2007, "pin_cites": [ { "page": "546" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/226/0515-01" ] }, { "cite": "222 Ill. 2d 218", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 3601786 ], "year": 2006, "pin_cites": [ { "page": "242" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/222/0218-01" ] }, { "cite": "186 Ill. 2d 472", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 243943 ], "year": 1999, "pin_cites": [ { "page": "490" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/186/0472-01" ] } ], "analysis": { "cardinality": 1486, "char_count": 42961, "ocr_confidence": 0.782, "pagerank": { "raw": 1.358979025993331e-07, "percentile": 0.6350926250912698 }, "sha256": "542c41f846f1a17e3317b4d72177fc3330f2a62f05e6b4aaaaf77ff953f80a5b", "simhash": "1:aab9031a49768bd1", "word_count": 6761 }, "last_updated": "2023-07-14T18:24:05.743057+00:00", "provenance": { "date_added": "2019-08-29", "source": "Harvard", "batch": "2018" }, "casebody": { "judges": [], "parties": [ "ROBERT N. POINDEXTER et al., Appellants, v. THE STATE OF ILLINOIS, Acting Through the Department of Human Services, et al., Appellees." ], "opinions": [ { "text": "JUSTICE FITZGERALD\ndelivered the judgment of the court, with opinion.\nChief Justice Thomas and Justices Freeman, Kilbride, Garman, Karmeier, and Burke concurred in the judgment and opinion.\nOPINION\nThis appeal arises out of the state\u2019s administrative efforts to recover from plaintiffs costs of their respective spouses\u2019 nursing home care. Rather than exhausting administrative remedies, plaintiffs filed a suit for declaratory and injunctive relief in the circuit court of Sangamon County. They asserted that the state spousal support provisions (305 ILCS 5/10 \u2014 1 through 10 \u2014 28 (West 2006); 89 Ill. Adm. Code \u00a7103.10 et seq.) were preempted by the Medicare Catastrophic Coverage Act of 1988 (MCCA) (42 U.S.C. \u00a71396r \u2014 5 (2000)). The circuit court found in favor of plaintiffs and enjoined the state from seeking spousal support. The appellate court reversed over a dissent. 372 Ill. App. 3d 1021. We granted plaintiffs leave to appeal (210 Ill. 2d R. 315(a)) and affirm the appellate court.\nBACKGROUND\nWe first discuss the federal provision at issue, then the state provision that is allegedly in conflict with it, and then the specific procedural facts of this case.\nA. Medicare Catastrophic Coverage Act\nMedicaid is a cooperative federal-state program authorized under Title XIX of the Social Security Amendments of 1965 (42 U.S.C. \u00a71396 et seq.). It provides medical services to both the categorically needy and the medically needy. Hines v. Department of Public Aid, 221 Ill. 2d 222, 227 (2006). Under prior law, a couple needed to deplete nearly all of their assets before either one could satisfy Medicaid eligibility requirements, leaving the spouse who remained in the community in a financially precarious position. H.R. Rep. No. 100 \u2014 105, at 69 (1988), reprinted in 1988 U.S.C.C.A.N. 857, 892. In 1988, Congress attempted to fix the Medicaid system to prevent \u201cspousal impoverishment.\u201d 42 U.S.C. \u00a71396r \u2014 5 (2000); Hines, 221 Ill. 2d at 228. The MCCA provided a formula for allowing the institutionalization of one spouse, while keeping the spouse remaining in the community some distance from the poverty line. H.R. Rep. No. 100 \u2014 105, at 69 (1988), reprinted in 1988 U.S.C.C.A.N. 857, 892.\nAnother goal of the MCCA was \u201cpreventing financially secure couples from obtaining Medicaid assistance.\u201d Wisconsin Department of Health & Family Services v. Blumer, 534 U.S. 473, 480, 151 L. Ed. 2d 935, 944, 122 S. Ct. 962, 967 (2002), citing H.R. Rep. No. 100 \u2014 105, at 65 (1988), reprinted in 1988 U.S.C.C.A.N. 857, 888. The MCCA prevented an \u201cinstitutionalized spouse\u201d from qualifying for Medicaid by transferring his or her interest in assets to the \u201ccommunity spouse.\u201d See H.R. Rep. No. 100 \u2014 105, at 73-74 (1988), reprinted in 1988 U.S.C.C.A.N. 857, 896-97; Johnson v. Guhl, 91 F. Supp. 2d 754, 761 (D.N.J. 2000) (with the MCCA, \u201cCongress intended to close the loophole where a couple could shelter resources in the community spouse\u2019s name while the institutionalized spouse received Medicaid\u201d). Therefore, the MCCA tried to balance two goals: \u201cpreventing impoverishment of the community spouse and ensuring that no one avoided contributing his or her fair amount to medical care.\u201d Thomas v. Commissioner of the Division of Medical Assistance, 425 Mass. 738, 740, 682 N.E.2d 874, 876 (1997).\nTo determine eligibility under these provisions, the state agency takes a \u201csnapshot\u201d of the couple\u2019s total current and forecasted resources and income as of the beginning of the first continuous period of institutionalization. See H.R. Rep. No. 100 \u2014 105, at 73-74 (1988), reprinted in 1988 U.S.C.C.A.N. 857, 896-97; Mistrick v. Division of Medical Assistance & Health Services, 154 N.J. 158, 171, 712 A.2d 188, 195 (1998); 42 U.S.C. \u00a71396r \u2014 5(c)(1)(A) (2000). Based on this snapshot, the agency attributes the couple\u2019s resources and income into spousal shares by a process of \u201cdeeming\u201d and \u201cdiversion.\u201d See M. Farley, When \u201cI Do\u201d Becomes \u201cI Don\u2019t\u201d: Eliminating the Divorce Loophole to Medicaid Eligibility, 9 Elder L.J. 27 (2001) (noting that the key provisions of the MCCA are the \u201cdeeming\u201d and \u201cdiversion\u201d provisions).\nThe MCCA\u2019s provisions consider both income and resources in determining an applicant\u2019s eligibility. Blumer, 534 U.S. at 481, 151 L. Ed. 2d at 944, 122 S. Ct. at 967. Under the income category, the institutionalized spouse\u2019s income cannot exceed the maximum level set by the state. However, the community spouse\u2019s income may not be \u201cdeemed available\u201d to the institutionalized spouse in determining eligibility. 42 U.S.C. \u00a71396r \u2014 5(b)(1) (2000). This is often called the \u201cname-on-the-check\u201d rule. Blumer, 534 U.S. at 481, 151 L. Ed. 2d at 944, 122 S. Ct. at 967. Under this rule, a community husband\u2019s income that he retains for himself will not, under state law, be counted against (or \u201cdeemed available\u201d to) his institutionalized spouse at the eligibility phase of the Medicaid process. Cf. Schweiker v. Gray Panthers, 453 U.S. 34, 44, 69 L. Ed. 2d 460, 470, 101 S. Ct. 2633, 2640 (1981).\nNext, the eligibility rules look at a couple\u2019s total resources. The state agency evaluates a couple\u2019s assets collectively, regardless of ownership. This collective evaluation of the couple\u2019s assets closed the loophole that allowed the couple to shelter resources solely in the name of the community spouse. A couple\u2019s total resources must be below a certain statutorily prescribed level called the \u201cCommunity Spouse Resource Allowance\u201d (CSRA) before the institutionalized spouse will be eligible. If the total resources are above this limit, the couple must \u201cspend down\u201d to gain eligibility. Houghton v. Reinertson, 382 F.3d 1162, 1165 (10th Cir. 2004); 42 U.S.C. \u00a71396r\u2014 5(c)(2) (2000).\nThe CSRA also diverts some of the institutionalized spouse\u2019s resources where the community spouse has little of his or her own resources. This may occur in the common case of a spouse who spent his or her entire career working in the home. To avoid having to \u201cspend down\u201d the entirety of a couple\u2019s assets to qualify the institutionalized spouse for Medicaid and thus impoverish himself or herself in the process, the community spouse is allowed to keep the CSRA. 42 U.S.C. \u00a71396r \u2014 5(f)(2) (2000). In other words, the state agency diverts some of the instititionalized spouse\u2019s assets to the community spouse to prevent spousal impoverishment. Conversely, if the community spouse retains most of the wealth, then his or her assets must be \u201cspent down\u201d only to the point of the CSRA.\nThe MCCA also provides diversion procedures regarding the couple\u2019s income to prevent spousal impoverishment. Once eligibility is reached, the state agency reexamines the ailing spouse\u2019s income to determine how much must be contributed toward nursing home costs and whether any of it should be left available to the community spouse. The institutionalized spouse is permitted to divert a portion of monthly income to the community spouse. This deduction from the institutionalized spouse\u2019s monthly income is known as the \u201ccommunity spouse monthly income allowance\u201d (CSMIA). 42 U.S.C. \u00a71396r\u2014 5(d)(1)(B) (2000). If the community spouse\u2019s income falls below the \u201cminimum monthly maintenance needs allowance\u201d (MMMNA), the agency allocates a portion of the institutionalized spouse\u2019s income to the community spouse. 42 U.S.C. \u00a71396r \u2014 5(d)(3) (2000). Thus, if the name-on-the-check rule does not provide the community spouse with this measure of sufficient income, the agency must look to the institutionalized spouse\u2019s income to bring the community spouse\u2019s income up to the MMMNA. 42 U.S.C. \u00a71396r \u2014 5(d)(6) (added by Pub. L. No. 109 \u2014 71, eff. February 8, 2006).\nFinally, the MCCA provides a \u201cfair hearing\u201d procedure through which a couple may challenge the results of the state agency\u2019s \u201csnapshot.\u201d At the fair hearing, also known as an \u201c(e)(2)(C) hearing,\u201d the state agency can address any dissatisfaction with the CSRA and the MMMNA. 42 U.S.C. \u00a71396r \u2014 5(e)(2)(C) (2000). For example, \u201c[i]f the couple succeeds in obtaining a higher CSRA, the institutionalized spouse may reserve additional resources for posteligibility transfer to the community spouse. The enhanced CSRA will reduce the resources the statute deems available for the payment of medical expenses; accordingly, the institutionalized spouse will become eligible for Medicaid sooner.\u201d Blumer, 534 U.S. at 483-84, 151 L. Ed. 2d at 946, 122 S. Ct. at 969.\nB. Spousal-Support Provisions\nAfter the institutionalized spouse has received benefits, a state agency may seek recovery of nursing home costs from the community spouse. Other states refer to this as a \u201cpay and chase\u201d system. Cf. 372 Ill. App. 2d at 1034 (referring to Connecticut\u2019s system, whereby it cannot refuse Medicaid eligibility based on a couple\u2019s resources, but then must seek contribution from the community spouse). The State of Illinois\u2019 spousal support provisions are found in article X of the Illinois Public Aid Code (305 ILCS 5/10 \u2014 1 through 10 \u2014 28 (West 2006)). When one spouse receives Public Aid, the other spouse is liable to the agency providing the benefits. 305 ILCS 5/10 \u2014 2 (West 2006). Section 10 \u2014 11 of the Code provides that if the appropriate state agency determines that a spouse owes support, the collections unit of that agency may issue an administrative order reflecting the amount owed to the state as reimbursement. 305 ILCS 5/10 \u2014 11 (West 2006).\nThe regulations promulgated by the state provide that the Illinois Department of Human Services \u201cshall seek to obtain support for recipients from legally responsible individuals and shall seek the enforcement of support obligations.\u201d 89 Ill. Adm. Code \u00a7103.10. However, \u201cthe Department shall not seek to obtain support for residents of long term care facilities if income of the spouse in the community is less than or equal to the\u201d MMMNA. 89 Ill. Adm. Code \u00a7103.10. In other words, the state may only recover from a community spouse whatever monies that spouse may have in addition to the MMMNA. Above that limit, 1% per month of the community spouse\u2019s gross annual income earned above $7,000 will be assessed as responsible-relative liability. 89 Ill. Adm. Code \u00a7103.20(a)(2); \u00a7103, Table A. The responsible family member must submit a copy of his or her most recent federal income tax return for this determination; otherwise that person is held liable for the full amount of the assistance provided. 89 Ill. Adm. Code \u00a7103.20.\nAn administrative support order becomes \u201cfinal\u201d if the person receiving the order fails to timely seek an administrative hearing. 305 ILCS 5/10 \u2014 12, 10 \u2014 13 (West 2006). Review of administrative findings may be made pursuant to section 10 \u2014 11 of the Public Aid Code (305 ILCS 5/10 \u2014 11 (West 2006)), and final agency determinations can be challenged under the Administrative Review Law (735 ILCS 5/3 \u2014 102 (West 2006)).\nC. Procedural History\nThe State of Illinois, acting through the Illinois Department of Public Aid (Public Aid) and the Illinois Department of Human Services (Human Services), administratively adjudged and sought spousal support from certain plaintiffs for their institutionalized spouses. Rather than proceeding with further administrative options, on July 22, 2004, plaintiffs Robert Poindexter, Mirl Whitaker, Maurice Hardy, Virginia McCulley, and Roger Meredith filed a complaint, in the circuit court of Sangamon County, for declaratory and injunctive relief against the state, Public Aid, Human Services, and the directors of the relevant state agencies (hereinafter, defendants).\nPlaintiffs alleged that each plaintiff was the \u201ccommunity spouse\u201d of an \u201cinstitutionalized spouse\u201d receiving medical assistance under the Medicaid program administered by the State of Illinois. Plaintiffs claimed that article X and its implementing regulations conflicted with the MCCA, and thus were preempted pursuant to the supremacy clause of the United States Constitution (U.S. Const., art. VI, cl. 2). The MCCA, according to plaintiffs, prohibited the collection of income from the community spouse after the eligibility determination. They principally cited section 1396r \u2014 5(b)(1), which provides as follows: \u201cDuring any month in which an institutionalized spouse is in the institution, except as provided in paragraph (2), no income of the community spouse shall be deemed available to the institutionalized spouse.\u201d 42 U.S.C. \u00a71396r \u2014 5(b)(1) (2000). According to plaintiffs, this section prohibits the state from seeking a contribution for the nursing home costs from the community spouse as long as the institutionalized spouse remained in the institution. Therefore, plaintiffs sought a declaration that Illinois\u2019 spousal support provisions, article X and its companion regulations, conflict with the MCCA and thus are preempted under the supremacy clause (U.S. Const., art. VI, cl. 2). Plaintiffs sought to permanently enjoin the defendants from undertaking any further collection efforts. They additionally asked for an order accounting for all the monies defendants had received from plaintiffs and requiring defendants to refund those sums, and to pay their litigation costs, expenses, and reasonable attorney fees.\nDefendants filed a motion to dismiss under section 2 \u2014 619(1) of the Code of Civil Procedure (735 ILCS 5/2\u2014 619(1) (West 2006)) based on plaintiffs\u2019 alleged failure to exhaust their administrative remedies as provided by the Public Aid Code and the Administrative Review Law. According to documents submitted by defendants to the trial court, plaintiff Poindexter had been issued an administrative order requiring him to pay $19,902 to reimburse Human Services for payments made on behalf of his wife. Human Services also issued Poindexter an ongoing assessment for her continued care of $1,210 a month. Poindexter did not seek a hearing from Human Services within the time provided by the Code. He also did not seek review of a subsequent order denying him a hearing because the request for a hearing he eventually made was untimely. Defendants also contended that plaintiffs Meredith and Hardy were subject to administrative support orders, but they also failed to seek administrative hearings with Human Services to contest the orders. Defendants\u2019 documents further showed that plaintiff Whitaker refused to answer a subpoena directed to him by Human Services requesting information regarding his income. Plaintiff McCulley also failed to provide Human Services with requested information, although a Human Services local office had information that her income from an annuity, beginning in November 2003, exceeded $8,300 per month. The trial court denied the defendants\u2019 motion to dismiss.\nThe original plaintiffs filed a motion entitled \u201cArgument,\u201d which the trial court treated as a motion for summary judgment. In ruling in favor of plaintiffs, the trial court noted the MCCA makes it clear that income is attributable to the spouse to whom it is paid, i.e., the \u201cname-on-the-check\u201d rule. Among other findings, the trial court stated:\n\u201c[T]he MCCA does not distinguish between eligibility and post-eligibility support, it rather plainly states: \u2018During any month in which an institutionalized spouse is in the institution; except as provided in paragraph (2), no income of the community spouse shall be deemed available to the institutionalized spouse.\u2019 The MCCA expressly states that \u2018no income\u2019 of a community spouse may be deemed available to an institutionalized spouse in \u2018any month,\u2019 during which the institutionalized spouse receives medical assistance.\u201d (Emphases in original.)\nThe trial court enjoined defendants from seeking any support from community spouses for any month in which the institutionalized spouse is receiving Medicaid. It also ordered that the plaintiffs recover costs and expenses.\nDefendants appealed, and the appellate court reversed. The appellate court first rejected the defendants\u2019 argument that plaintiffs failed to exhaust administrative remedies. The appellate court found that the issue raised was purely one of law and \u201cis not an issue that falls within the particular expertise of an administrative agency, especially considering it involves the interpretation of a federal statute.\u201d 372 Ill. App. 3d at 1025. The court noted that unlike the situation presented in Arvia v. Madigan, 209 Ill. 2d 520 (2004), none of plaintiffs\u2019 claims are specifically required by statute to be brought before an administrative law judge. Further, following Arvia, plaintiffs\u2019 claims are purely constitutional and there are no factual disputes. 372 Ill. App. 3d at 1025-26.\nNext, the appellate court addressed the preemption issue. The court examined the language of the MCCA and stated:\n\u201cThe introductory language of the MCCA clearly states that the provisions of the MCCA are for the purposes of determining Medicaid eligibility, which would not include issues involving ongoing spousal support. To read the subsection that states \u2018no income of the community spouse\u2019 that plaintiffs rely on as extending beyond the scope of an eligibility determination would essentially render the introductory language meaningless.\u201d 372 Ill. App. 3d at 1029.\nThe court also noted that the word \u201cdeem\u201d is a term of art in the Medicaid context, used for purposes of determining eligibility. 372 Ill. App. 3d at 1029. Assets owned by each spouse are added together, and each spouse is \u201cdeemed\u201d to own half, irrespective of any state\u2019s laws concerning community property. 372 Ill. App. 3d at 1029-30, citing Schweiker, 453 U.S. at 44-45, 69 L. Ed. 2d at 470, 101 S. Ct. at 2640-41. Since the MCCA clearly indicates that it is intended to apply to determinations of eligibility, the clause plaintiffs rely on, \u201cno income of the community,\u201d is clearly only in relation to determinations of eligibility. 372 Ill. App. 3d at 1029. Justice Knecht dissented, stating, in part: \u201cI agree with the trial court: the MCCA restricts the State from seeking support from the income of a community spouse, even if his or her income is more than the monthly needs allowance, for his or her \u2018institutionalized spouse\u2019 receiving Medicaid.\u201d 372 Ill. App. 3d at 1036 (Knecht, J., dissenting).\nWe granted leave to appeal (210 Ill. 2d R. 315(a)).\nANALYSIS\nWe address two issues: whether plaintiffs were required to exhaust administrative remedies before they sought declaratory and injunctive relief in circuit court; and whether the MCCA preempts state spousal support provisions.\nI\nWe first address defendants\u2019 contention that plaintiffs\u2019 complaint for declaratory relief pursuant to the Illinois declaratory judgment statute (735 ILCS 5/2\u2014 701(a) (West 2006)) should be dismissed due to failure to exhaust administrative remedies. Section 2 \u2014 619 permits a dismissal after the trial court considers issues of law or easily proved issues of fact. 735 ILCS 5/2 \u2014 619 (West 2006); Czarobski v. Lata, 227 Ill. 2d 364 (2008). The question on appeal is \u201cwhether the existence of a genuine issue of material fact should have precluded the dismissal or, absent such an issue of fact, whether dismissal is proper as a matter of law.\u201d Kedzie & 103rd Currency Exchange, Inc. v. Hodge, 156 Ill. 2d 112, 116-17 (1993). Our review proceeds de novo. Czarobski v. Lata, 227 Ill. 2d at 369.\nDefendants first argue that plaintiffs Poindexter, Meredith, and Hardy failed to exhaust administrative remedies, including failing to raise their constitutional claim at the administrative level. Defendants cite two statutes as affirmative matter to defeat the plaintiffs\u2019 complaint: (1) before filing suit, plaintiffs failed to exhaust their administrative remedies, as required by section 10 \u2014 11, of the Public Aid Code (305 ILCS 5/10 \u2014 11 (West 2006)); and (2) plaintiffs were required to file an administrative review complaint under the Administrative Review Law (735 ILCS 5/3 \u2014 102 (West 2006)). Plaintiffs respond that this is a facial challenge to the statute, falling within a recognized exception to the exhaustion doctrine.\nCourts apply the exhaustion doctrine to declaratory judgment actions. Beahringer v. Page, 204 Ill. 2d 363, 374 (2003). Generally, a party aggrieved by an administrative action must first pursue all available administrative remedies before resorting to the courts. Canel v. Topinka, 212 Ill. 2d 311, 320 (2004). The purpose of the exhaustion doctrine is to allow administrative bodies to develop a factual record and to permit them to apply the special expertise they possess. Canel, 212 Ill. 2d at 320-21. Exhaustion also minimizes interruption of the administrative process. Moreover, the aggrieved party might succeed before the administrative body, obviating the need for judicial involvement, thereby conserving judicial resources. Canel, 212 Ill. 2d at 320-21. If a challenging party alleges that a facially valid statute has been applied in an arbitrary or discriminatory manner, \u201c \u2018the rule generally prevails that recourse must be had in the first instance to the appropriate administrative board.\u2019 \u201d Beahringer, 204 Ill. 2d at 374, quoting Bank of Lyons v. County of Cook, 13 Ill. 2d 493, 495 (1958). The exhaustion doctrine also precludes review where the Administrative Review Law provides a remedy. Canel, 212 Ill. 2d at 321.\nA party who challenges the validity of a statute on its face, however, is not required to exhaust administrative remedies. Arvia, 209 Ill. 2d at 532. \u201cThe reason for this exception is apparent: administrative review is confined to the proofs offered and the record created before the agency.\u201d Arvia, 209 Ill. 2d at 532-33. \u201cA facial attack to the constitutionality of a statute, which presents purely legal questions, is not dependent for its assertion or its resolution on the administrative record.\u201d Arvia, 209 Ill. 2d at 533; see also Canel, 212 Ill. 2d at 321 (\u201cAn aggrieved party may seek judicial review of an administrative decision without complying with the exhaustion of remedies doctrine where a statute *** is attacked as unconstitutional on its face\u201d); Landfill, Inc. v. Pollution Control Board, 74 Ill. 2d 541, 550 (1978) (\u201cExhaustion is not required where a statute or rule under which an administrative body purports to act is challenged as unauthorized, since the judicial determination will affect the jurisdiction of the administrative body in all matters, not only in the instant circumstances\u201d). Further, there is virtually no chance the aggrieved party will succeed before an agency where the issue is the agency\u2019s own assertion of authority. Landfill, 74 Ill. 2d at 550-51.\nHere, we are asked to decide whether the MCCA preempts the spousal support law: a direct challenge to the authority of the defendants to act in this manner. There has been no allegation that the defendants misapplied the statute or regulation at issue or applied it in an arbitrary manner. The complaint alleges Illinois\u2019 provisions conflict with federal law in violation of the United States Constitution. Therefore, this matter falls squarely within an exception to the exhaustion requirement, and defendants\u2019 argument on this point is rejected.\nWe next reject defendants\u2019 argument that six of the other plaintiffs, Whitaker, McCulley, Davis, Josephson, Gonet, and Dickens, should have been dismissed because they had not yet received final administrative orders, citing National Marine, Inc. v. Illinois Environmental Protection Agency, 159 Ill. 2d 381 (1994). We first note that defendants never filed a motion to dismiss as to plaintiffs Whitaker, Davis, Josephson, Gonet, or Dickens. Nevertheless, even if defendants\u2019 motions as to those plaintiffs were not forfeited, we would reject it. In National Marine, we noted that in cases involving challenges to administrative actions, application of the ripeness doctrine prevents courts \u201c \u2018 \u201cfrom entangling themselves in abstract disagreements over administrative policies\u201d \u2019 \u201d and \u201c 1 \u201cprotect[s] the agencies from judicial interference until an administrative decision has been formalized and its effects felt in a concrete way by the challenging parties.\u201d \u2019 \u201d National Marine, 159 Ill. 2d at 388, quoting Bio-Medical Laboratories, Inc. v. Trainor, 68 Ill. 2d 540, 546 (1977), quoting Abbott Laboratories v. Gardner, 387 U.S. 136, 148-49, 18 L. Ed. 2d 681, 691, 87 S. Ct. 1507, 1515 (1967). There, the Illinois Environmental Protection Agency had issued a notice informing the plaintiff that it could be potentially liable for a \u201c \u2018release or a substantial threat of a release of a hazardous substance\u2019 \u201d on the property pursuant to section 4(q) of the Act. National Marine, 159 Ill. 2d at 383, quoting Ill. Rev. Stat. 1991, ch. llU/a, par. 1004(q). This court noted that the \u201ccomplaint, in essence, sought to obtain judicial review of the Agency\u2019s issuance of the 4(q) notice prior to the Agency\u2019s initiation of cost-recovery/enforcement proceedings before the Pollution Control Board (Board) or the circuit court.\u201d National Marine, 159 Ill. 2d at 385. We found, \u201cat this preliminary stage in the administrative process, it is not clear whether the Agency will even initiate a cost-recovery/enforcement proceeding against plaintiff before one of these bodies. Clearly, under the circumstances, plaintiffs complaint is premature.\u201d National Marine, 159 Ill. 2d at 390-91.\nNone of those considerations are present in this case. Both parties admit that there are no issues of fact and that an interpretation of the MCCA in light of the spousal support laws is all that is required. The monetary amounts have been determined and are not challenged by the community spouses. Unlike National Marine, in this case there are no abstract issues that this court faces. We therefore reject defendants\u2019 exhaustion argument and turn to consideration of whether article X is preempted by the MCCA.\nII\nAs to the preemption issue, plaintiffs submitted to the trial court a brief entitled \u201cArgument,\u201d which the defendants, the trial court and the appellate court treated as a motion for summary judgment. Because both parties agree that this case requires only an interpretation of the MCCA in light of Illinois\u2019 spousal support provisions, and admit that there are no issues of fact, we will do the same. Summary judgment is appropriate where the pleadings show that there is no genuine issue as to any material fact. 735 ILCS 5/2 \u2014 1005(c) (West 2006). All cases involving summary judgment are reviewed de novo. Sun Life Assurance Co. of Canada v. Manna, 227 Ill. 2d 128 (2007); see also Kinkel v. Cingular Wireless, LLC, 223 Ill. 2d 1, 15 (2006) (\u201c[wjhether state law is preempted by a federal statute is a question of law, subject to de novo review\u201d).\nThe supremacy clause of the United States Constitution provides that \u201c[t]his Constitution, and the Laws of the United States *** shall be the supreme Law of the Land *** any Thing in the Constitution or Laws of any State to the Contrary notwithstanding.\u201d U.S. Const., art. VI, cl. 2. \u201cState law is preempted under the supremacy clause in three circumstances: (1) when the express language of a federal statute indicates an intent to preempt state law; (2) when the scope of a federal regulation is so pervasive that it implies an intent to occupy a field exclusively; and (3) when state law actually conflicts with federal law.\u201d Village of Mundelein v. Wisconsin Central R.R., 227 Ill. 2d 281, 288 (2008), citing English v. General Electric Co., 496 U.S. 72, 78-79, 110 L. Ed. 2d 65, 74, 110 S. Ct. 2270, 2275 (1990). The determination of whether state law is preempted turns on the intent of Congress. Village of Mundelein, 227 Ill. 2d at 288, citing Wisconsin Public Intervenor v. Mortier, 501 U.S. 597, 604, 115 L. Ed. 2d 532, 542, 111 S. Ct. 2476, 2481 (1991).\nHere, although plaintiffs apparently contend that all three circumstances are present in this case, their arguments as to the first two circumstances amount to little more than one-sentence conclusions. See In re Marriage of Bates, 212 Ill. 2d 489, 517 (2004) (\u201cA reviewing court is entitled to have issues clearly defined with relevant authority cited\u201d). Rather, plaintiffs\u2019 argument centers on the third circumstance of preemption, whether the state law actually conflicts with federal law. Plaintiffs contend that MCCA section 1396r \u2014 5(b)(1) prohibits defendants from collecting spousal support under article X. Defendants argue that section 1396r \u2014 5(b)(1) applies only to eligibility determinations. They emphasize eligibility language throughout the MCCA, and also point out that the \u201cdeemed eligible\u201d language contained in subsection (b)(1) applies only to eligibility determinations. We agree with defendants.\nA careful review of the language of the MCCA reveals an absence of consideration of the spousal support laws of which plaintiffs complain. Rather, it sets out a mechanism of deeming and diversion to implement the MCCA\u2019s twin goals of ameliorating spousal impoverishment and \u201cpreventing financially secure couples from obtaining Medicaid assistance.\u201d Blumer, 534 U.S. at 480, 151 L. Ed. 2d at 944, 122 S. Ct. at 967, citing H.R. Rep. No. 100 \u2014 105, at 65 (1988). To achieve this, Congress directed that the state agency, in making its eligibility determination, take a \u201csnapshot\u201d of the couple\u2019s current and future resources to determine what income needed to be deemed to the institutionalized spouse and what income needed to be diverted to the community spouse. This is indicated in several ways.\nWe first examine the introductory section, subsection (a), which reveals it is aimed at determining \u201celigibility,\u201d as it states:\n\u201c(a) Special treatment for institutionalized spouses (1) Supersedes other provisions In determining the eligibility for medical assistance of an institutionalized spouse *** the provisions of this section supersede any other provision of this subchapter *** which is inconsistent with them.\u201d (Emphasis added.) 42 U.S.C. \u00a71396r \u2014 5(a)(1) (2000).\nThis indicates the statute concerns rules enabling institutionalization of an ailing spouse. Thus, the remainder of the statute is to be read with this eligibility determination in mind. Notably absent from this section is any language prohibiting a state from obtaining reimbursement of medical expenditures through spousal support laws.\nNext, we note that the MCCA\u2019s provisions concerning \u201crules for treatment of income,\u201d found in subsection (b), relate to this eligibility determination. It contains two subsections: (b)(1), entitled \u201cseparate treatment of income\u201d \u2014 the name-on-the-check rule \u2014 which relates to deeming; and (b)(2), entitled \u201cattribution of income,\u201d which relates to diversion.\nThe name-on-the-check rule properly assures that the Medicaid eligibility determination for the ailing spouse takes into account only income over which the ailing spouse has actual control. It provides:\n\u201c(1) Separate Treatment of Income During any month in which an institutionalized spouse is in the institution, except as provided in paragraph (2), no income of the community spouse shall be deemed available to the institutionalized spouse.\u201d (Emphasis added.) 42 U.S.C. \u00a71396r \u2014 5(b)(1) (2000).\nThis provision prevents the state agency from looking at a community spouse\u2019s income to prevent the receipt of benefits by an ailing spouse. Furthermore, this section of the statute does not reference spousal support laws in any way.\nMoreover, this section \u2014 the name-on-the-check rule\u2014 uses a term of art, \u201cdeemed available,\u201d which points to eligibility determinations. The United States Supreme Court explained the genesis of this \u201cdeemed available\u201d language, stating, \u201cUntil 1989, the year the MCCA took effect, States generally considered the income of either spouse to be \u2018available\u2019 to the other. We upheld this approach in Gray Panthers, observing that \u2018from the beginning of the Medicaid program, Congress authorized States to presume spousal support.\u2019 \u201d Blumer, 534 U.S. at 479, 151 L. Ed. 2d at 944, 122 S. Ct. at 967, quoting S. Rep. No. 89 \u2014 404, at 78 (1965), reprinted in 1965 U.S.C.C.A.N. 1943, 2018. The Court then described how the MCCA changed this determination after 1989\u2014 providing that a spouse\u2019s income shall not be deemed available to the other. It stated, referring to subsection (b)(1), \u201cThe community spouse\u2019s income is thus preserved for that spouse and does not affect the determination whether the institutionalized spouse qualifies for Medicaid. In general, such income is also disregarded in calculating the amount Medicaid will pay for the institutionalized spouse\u2019s care after eligibility is established.\u201d Blumer, 534 U.S. at 480-81, 151 L. Ed. 2d at 944, 122 S. Ct. at 967. Further, as the United States Supreme Court observed in Blumer, this \u201cdeemed available\u201d language applied to the couple\u2019s resources as well. Blumer, 534 U.S. at 479-80, 151 L. Ed. 2d at 944, 122 S. Ct. at 967 (\u201cSimilarly, assets held jointly by the couple were commonly deemed \u2018available\u2019 in full to the institutionalized spouse\u201d (emphasis added)). Accordingly, subsection (b)(1) must be construed in light of the MCCA mechanisms to avoid spousal impoverishment and prevent financially secure couples from receiving benefits. Indeed, our research reveals that prior courts have only construed this language in terms of its effect on the institutionalized spouse\u2019s eligibility. See, e.g., Arkansas Department of Health & Human Services v. Smith, 370 Ark. 490, 262 S.W3d 167 (2007); In re Estate of Tomeck, 8 N.Y.3d 724, 872 N.E.2d 236, 840 N.Y.S.2d 550 (2007); King v. Secretary, Louisiana Department of Health & Hospitals, 956 So. 2d 666 (La. App. 2007).\nThe next \u201crule for treatment of income,\u201d subsection (b)(2), provides guidance for \u201cdetermining the income of an institutionalized spouse or community spouse for purposes of the post-eligibility income determination described in subsection (d).\u201d 42 U.S.C. \u00a71396r \u2014 5(b)(2) (2000). The language of subsection (b)(2) is limited to attributing income between spouses to provide the income values needed in subsection (d) and was not directed to state spousal support laws. In turn, subsection (d) is entitled \u201cProtecting income for community spouse\u201d and refers to a procedure for raising an impoverished community spouse\u2019s income. 42 U.S.C. \u00a71396r \u2014 5(d) (2000). Subsections (d)(1)(B), (d)(2), and (d)(3) provide for the allocation of available income from the institutionalized spouse to the community spouse to maintain a minimum monthly income, or MMMNA, when the community spouse\u2019s own income is below that level. 42 U.S.C. \u00a71396r \u2014 5(d)(2) (2000). Subsection (2) defines the difference between the MMMNA and the community spouse\u2019s income as the \u201ccommunity spouse monthly income allowance.\u201d 42 U.S.C. \u00a71396r \u2014 5(d)(2) (2000). The community spouse monthly income allowance, along with other allowances defined in subsection (d), is deducted from the institutionalized spouse\u2019s income before determining the amount of the institutionalized spouse\u2019s income, as determined in subsection (b), must be paid toward the costs of institutional care. Thus, Congress intended subsection (d) to prevent impoverishment of the community spouse by permitting income to be allocated to that spouse from the institutionalized spouse when necessary. This provision is not directed at spousal support laws such as article X, where the community spouse may be required to reimburse the state for some of the cost of care provided to the institutionalized spouse.\nFinally, the remainder of the MCCA regarding the CSRA, MMMNA and the \u201cfair hearing\u201d is peppered with language referring to the eligibility determination when the agency takes its \u201csnapshot.\u201d See 42 U.S.C. \u00a7\u00a71396r\u2014 5(c)(1) (\u201cComputation of spousal share at time of institutionalization\u201d), 1396r \u2014 5(c)(1)(A) (\u201cThere shall be computed [ ]as of the beginning of the first continuous period of institutionalization\u201d), 1396r \u2014 5(c)(1)(B) (\u201cAt the request of an institutionalized spouse or community spouse, at the beginning of the first continuous period of institutionalization\u201d), 1396r \u2014 5(c)(2) (\u201cAttribution of resources at time of initial eligibility determination[.] *** In determining the resources of an institutionalized spouse at the time of application for benefits under this subchapter\u201d), 1396r \u2014 5(d)(1) (\u201cAfter an institutionalized spouse is determined or redetermined to be eligible for medical assistance\u201d), 1396r \u2014 5(e)(1)(A) (\u201ca determination of eligibility\u201d), 1396r \u2014 5(e)(2)(A) (\u201cIf either *** spouse is dissatisfied with a determination of\u2019), 1396r\u2014 5(e)(2)(A) (\u201cwith respect to such determination if an application for benefits under this subchapter has been made on behalf of the institutionalized spouse\u201d). These provisions indicate that the MCCA is only concerned with \u201cdiversion\u201d after eligibility has been determined. It makes no further provisions for the income of a community spouse which may be above the MMMNA, except to the extent that a community spouse may request a \u201cfair hearing\u201d to raise the MMMNA or CSRA.\nThus, the community spouse\u2019s income becomes an issue only when he or she does not receive sufficient income to cover the basic costs of living. In that case, he or she may seek, through a \u201cfair hearing,\u201d a portion of the institutionalized spouse\u2019s income to help defray necessary costs. This accords with the purposes of the Act: to prevent impoverishment of the community spouse and to prevent financially secure couples from receiving benefits. As the court illustrated in Blumer,\n\u201cAlthough that hearing is conducted preeligibility, its purpose is to anticipate the posteligibility financial situation of the couple. The procedure seeks to project what the community spouse\u2019s income will be when the institutionalized spouse becomes eligible. See Tr. of Oral Arg. 14 (officer conducting (e)(2)(C) hearing makes a calculation that \u2018concerns the post eligibility period\u2019; question is will \u2018the at-home spouse ... have sufficient income in the post eligibility period, or does the resource allowance need to be jacked up in order to provide that additional income\u2019). The hearing officer must measure that projected income against the MMMNA, a standard that, like the CSMIA, is operative only posteligibility.\u201d (Emphases in original.) Blumer, 534 U.S. at 491, 151 L. Ed. 2d at 951, 122 S. Ct. at 973.\nAccordingly, while the MCCA addresses the posteligibility income of a potentially impoverished spouse, it says nothing about the state\u2019s ability to seek reimbursement from an otherwise financially secure community spouse;\nThe plaintiffs further argue the appellate court improperly limited the MCCA to the first eligibility determination, pointing out that eligibility is an ongoing, monthly proposition. But the court did not do so; it merely stated that the eligibility determination does not include issues of ongoing spousal support owed to the state. 372 Ill. App. 3d at 1029. Nevertheless, although an institutionalized spouse\u2019s Medicaid eligibility may be redetermined each month, this is irrelevant to the community spouse\u2019s state-law obligation to pay spousal support when their community-spouse income exceeds the MMMNA.\nWe therefore find that the MCCA does not preempt article X of the Public Aid Code. Accordingly, the appellate court correctly reversed the trial court\u2019s grant of declaratory, injunctive, and other relief to the plaintiffs.\nCONCLUSION\nFor the foregoing reasons, we find that plaintiffs were not required to exhaust administrative remedies and that the MCCA does not preempt article X of the Public Aid Code. Therefore, we affirm the judgment of the appellate court which reversed the trial court.\nAffirmed.\nA11 nonexcludable resources of both spouses over and above the CSRA are to be available to pay for nursing care costs of the institutionalized spouse. See 42 U.S.C. \u00a7\u00a71396r \u2014 5(c)(1)(A), (c)(2) (2000) . The remaining resources in excess of the community resource allowance are considered available to the institutionalized spouse, who will be eligible for Medicaid only if those remaining resources are less than or equal to $2,250. 20 C.F.R. \u00a7416.1205 (2001) . Any and all resources above the CSRA must then be spent before an institutionalized spouse will be eligible for medicaid.\nThe MMMNA is calculated by multiplying the federal poverty level for a couple by a percentage set by the states. Since 1992, that percentage must be at least 150% (42 U.S.C. \u00a7\u00a71396r\u2014 5(d)(3)(A), (d)(3)(B) (2000)), but the resulting MMMNA may not exceed $1,500 per month in 1988 dollars. 42 U.S.C. \u00a7\u00a71396r\u2014 5(d)(3)(C), (g) (2000). At the time of litigation in this case, the Illinois MMMNA, called in Illinois the \u201cCommunity Spouse Maintenance Needs Standard,\u201d was $2,378.\nThe trial court later allowed motions to join by Orville Davis, Catherine Josephson, Margaret Gonet, and Mary Lou Dickens. They all alleged that they were community spouses of institutionalized spouses, that the issues were the same as those of the other plaintiffs, and that granting the motion would be in the interests of judicial economy. The record does not reveal that defendants filed a specific motion to dismiss as to these plaintiffs.\nPlaintiffs initially challenge this argument by claiming that defendants were required to raise it in a cross-appeal. We disagree. Rule 318(a) (155 Ill. 2d R. 318(a)) provides that in all appeals \u201cany appellee, respondent, or coparty may seek and obtain any relief warranted by the record on appeal without having filed a separate petition for leave to appeal or notice of cross-appeal or separate appeal.\u201d This court has invoked Rule 318(a) in finding that allowance of one party\u2019s petition for leave to appeal brings before this court the other party\u2019s requests for cross-relief. See Heastie v. Roberts, 226 Ill. 2d 515, 546 (2007); Tri-G, Inc. v. Burke, Bosselman & Weaver, 222 Ill. 2d 218, 242 (2006); Weatherman v. Gary-Wheaton Bank of Fox Valley, N.A., 186 Ill. 2d 472, 490 (1999). We do note, however, that plaintiffs correctly point out that the cover of defendants\u2019 brief did not request cross-relief. Rule 315(h) provides: \u201cIf the brief of the appellee contains arguments in support of cross-relief, the cover of the brief shall be captioned: \u2018Brief of Appellee. Cross-Relief Requested.\u2019 \u201d 210 Ill. 2d R. 315(h).\nPlaintiffs do not argue that defendants\u2019 spousal support provisions threaten to impoverish them in violation of the MCCA. They further do not argue that they could potentially make use of this fair hearing mechanism in order to protect any of their income from defendant\u2019s spousal support order.", "type": "majority", "author": "JUSTICE FITZGERALD" } ], "attorneys": [ "Duane D. Young and Dawn D. Behnke, of LaBarre, Young & Behnke, of Springfield, for appellants.", "Lisa Madigan, Attorney General, of Springfield (Michael A. Scodro, Solicitor General, and Carl J. Elitz and Elaine Wyder-Harshman, Assistant Attorneys General, of Chicago, of counsel), for appellees." ], "corrections": "", "head_matter": "(No. 104853.\nROBERT N. POINDEXTER et al., Appellants, v. THE STATE OF ILLINOIS, Acting Through the Department of Human Services, et al., Appellees.\nOpinion filed April 3, 2008.\nRehearing denied May 27, 2008.\nDuane D. Young and Dawn D. Behnke, of LaBarre, Young & Behnke, of Springfield, for appellants.\nLisa Madigan, Attorney General, of Springfield (Michael A. Scodro, Solicitor General, and Carl J. Elitz and Elaine Wyder-Harshman, Assistant Attorneys General, of Chicago, of counsel), for appellees." }, "file_name": "0194-01", "first_page_order": 208, "last_page_order": 231 }