Actuarial Soundness, the Meaning of "Commensurate," and a "Sniff Test".

The article uses the case Zahner v. Secretary of Pennsylvania Department of Human Services, wherein Deficit Reduction Act (DRA)-compliant annuities were used by plaintiffs to conform to Medicaid requirements, as a framework for discussing actuarial soundness, the meaning of commensurate and the Sniff Test. Issues tackled are purchase of annuities in connection with eligibility of Medicaid beneficiaries, annuity safe harbor under the Medicaid Act, and annuities considered as trust-like devices.