Plan to apply for Medicaid (expecting a penalty period).

I posted my situation earlier and received some great feedback. Applying that and other research, I came up with this plan.

Hoping someone can review my plan to see if it's sound (mother-in-law approves)

Mother-in-law (86) moved in with us (Henderson, NV) in May 2023.

For the past year, she has lived in Reno with her daughter.

Prior to that, she lived in senior housing in Southern California for 20 years. During that time, all of her income (social security, $530, SSI $230) except $100 went for rent and utilities. She made a little side money, sewing, which she saved for her funeral, not wanting to burden her children.

While in Reno, her side money plus what she accumulated in social security (not paying daughter rent) added up to $12,000 in the bank. For 20+ years, no assets, minimal income, until this past year.

She is somewhat frail, weak, uses a walker to get around. Goes to the restroom without assistance. Showers with assistance. She has the normal healthcare issues (hypertension, etc.). Greatest risk, besides a new catastrophic illness, would be falling and breaking a hip.

She has a Medicare Advantage plan. She is not our dependent for tax purposes.

My plan:

1. Goal: Get her approved for Medicaid to help with out-of-pocket (Medicare Advantage) healthcare costs and to help if she should need to move in to a nursing home (hopefully, not in the near future).

2. Complete a Living Will, Durable Power of Attorney.

3. She will gift $10,500 to her daughter, dropping her assets to less than $2000.

4. She will pay rent, $430/month (so as not to accumulate assets > $2000) with written rental agreement in place.

5. When we apply for Medicaid, will report her income ($530/month, SSI was dropped), the gift she gave, and her assets of <$2000.

The Nevada penalty divisor is $9000. Medicaid will apply the penalty of 1.5 months of ineligibility, and she will be Medicaid eligible/approved after 1.5 months goes by.

Am I missing anything?