Jerry Glover, an 82-year-old nursing-home resident, bought an irrevocable, nonassignable, actuarially sound annuity before applying for Medicaid. Georgia’s Department of Human Services imposed an asset-transfer penalty because the annuity did not name the State as a remainder beneficiary. An administrative law judge initially reversed the penalty, but the Department of Community Health upheld it; the superior court affirmed, and the Court of Appeals reversed. The Supreme Court of Georgia held that the federal Medicaid statute was ambiguous about the relationship between its State-beneficiary requirement and its separate provisions concerning actuarially sound annuities. Because the Department of Community Health administers Georgia’s Medicaid plan, the Court deferred to its reasonable interpretation, adopted from federal agency guidance, that an annuity must satisfy both sets of requirements to avoid a penalty. The Court therefore reversed the Court of Appeals and reinstated the agency decision. Justice Nahmias, joined by Justice Blackwell, concurred specially: he agreed with the result but questioned whether an agency opinion letter and policy manual warranted full Chevron deference, concluding that the agency interpretation was persuasive even under a less demanding standard.