In this challenge to the Indiana Family and Social Services Administration’s (FSSA) automated system of processing claims for Medicaid, Food Stamps, and Temporary Assistance to Needy Families (TANF) benefits, we reverse the judgment of the trial court and hold that the FSSA’s denial notices are insufficiently explanatory but that the FSSA may deny an application for Food Stamp benefits when the applicant fails to cooperate in the eligibility determination process. We affirm in part the trial court’s grant of Perdue’s motion for summary judgment and hold that Sheila Perdue is entitled to reasonable accommodations in applying for benefits but that this does not necessarily require providing a caseworker or case management services.
… Merely offering applicants information from which they could potentially deduce the reasons for a denial is no process at all. Notice must be unambiguous so that applicants can know the precise reason for which they were denied benefits and can determine the accuracy of the State’s determination. Form 2032 offers no additional information concerning the reasons for the State’s decision in a particular case. It in no way explains the underlying reasons for the FSSA’s denial of benefits. At best, Form 2032 aids the applicant in deducing the reasons for the denial, but it does not inform the applicant of the specific reason for the adverse determination. [Footnote omitted.]
We therefore hold, as a matter of law, that the notices used by the FSSA to inform individuals that their applications for Medicaid, Food Stamp, or TANF benefits have been denied do not satisfy the requirements of due process. Accordingly, the Class A and Sub-class A plaintiffs were entitled to summary judgment on this issue, and the State’s motion for summary judgment should have been denied.
… we hold that federal law permits the FSSA to deny benefits to applicant’s who fail to cooperate in the eligibility determination process. We therefore reverse the trial court’s grant of summary judgment to the plaintiffs on this issue.
3. Sheila Perdue
… Because the FSSA does not know before an applicant’s eligibility is determined whether a disabled individual is legally entitled to benefits, it must reasonably accommodate all disabled individuals during the application process so as not to inadvertently burden qualified disabled applicants. Perdue has designated sufficient facts to support a finding that she was denied meaningful access to the FSSA’s pro-grams because anyone is eligible to apply for Food Stamp and Medicaid benefits.
Having concluded that the FSSA violated Perdue’s rights under the ADA and RA, the trial court ordered the FSSA to provide her with a “caseworker or case management services.” Findings of Fact, Conclusions of Law, and Summary Judgment, Appellants’ App’x at 38. The trial court’s order was premised on the Second Circuit’s conclusion in Henrietta D. v. Bloomberg, that the case management system utilized by New York City in that case represented a reasonable accommodation. Id. at 36 (citing 331 F.3d 261, 280 (2d Cir. 2003)). Henrietta D., however, does not stand for the proposition that a case management system is the only reasonable accommodation sufficient to accommodate disabled applicants for social services. It stands only for the proposition that such a system is a sufficient reasonable accommodation. 331 F.3d at 280. The ADA and RA only require that the FSSA provide meaningful access to the disabled unless such “reasonable accommodation . . . would impose an undue hardship on the operation of its program.” See id., 331 F.3d at 281–82 (citing 28 C.F.R. § 41.53). Thus, the FSSA is not required to adopt any specific form of accommodation such as a caseworker or case management services. Rather, the FSSA is only required to make reasonable accommodations sufficient to accommodate the disabled.
Summary judgments in favor of the State as to Class A and Sub-class A and in favor of the plaintiffs as to Class C are reversed, and summary judgment in favor of Sheila Perdue is af-firmed in part. With respect to Class A and Sub-class A, we grant the plaintiffs’ motion for summary judgment and hold that the notices used by the FSSA to inform applicants that they have been denied Medicaid, Food Stamp, and TANF benefits are unconstitutional under the Due Process Clause of the Fourteenth Amendment to the United States Constitution because they fail to sufficiently explain the reasons underlying the agency’s adverse determination. On this issue, this case is remanded to the trial court to adjudicate the plaintiffs’ related claims for relief. With respect to Class C, we reverse the grant of the plaintiffs’ motion for summary judgment and hold that federal law permits the FSSA to deny an application for Food Stamp benefits when the applicant fails to cooperate in the eligibility determination process. With respect to Sheila Perdue, we affirm in part the trial court’s grant of Perdue’s motion for summary judgment to hold that she is entitled to reasonable accommodation, but we decline to require that the State necessarily must provide a caseworker or case management services.
Shepard, C.J., and Sullivan, Rucker, and David, JJ., concur.