A federal appeals court ruled that Florida failed to adequately explain to Medicaid recipients why their coverage was being cut during the state's post-COVID eligibility reviews.

The Nov. 4 decision by the U.S. Court of Appeals for the Eleventh Circuit upholds a permanent injunction ordering the state to clearly spell out its reasons before terminating anyone's Medicaid benefits for financial ineligibility. The ruling covers a certified class of all Florida Medicaid enrollees who received income-based termination notices lacking that information on or after March 31, 2023, according to the court opinion.

For Hillsborough County residents, including families in Apollo Beach and Ruskin, the decision means the state must now include specific details in any letter cutting Medicaid coverage: the household size it used, the income it counted, the eligibility category it applied and the income limit for that category.

What the court found

U.S. Circuit Judge Barbara Lagoa wrote the 23-page opinion. After a six-day bench trial, the lower court found that the notices did not "unambiguously communicate the State's decision to terminate benefits, the reason for that decision, or to whom it applies," Lagoa wrote. "We agree."

The case centered on the state's Department of Children and Families (DCF), which determines Medicaid eligibility, and the Agency for Health Care Administration (AHCA), which administers the program. Between April 2023 and March 2024, DCF redetermined the eligibility of more than four million people after the federal COVID-era freeze on disenrollments ended, as first reported by WUSF.

The court found the termination letters were so confusing that even the state's own employees misread them.

One mother's notice

The lead plaintiff, identified in court papers as Chianne D., received an 11-page notice in April 2023 stating she and her newborn son were being dropped for financial reasons. One section listed both as ineligible because "your household's income is too high." Several pages later, a different section said her son remained eligible.

The notice did not include the family's size, the qualifying income limit or Chianne D.'s reported monthly income. When she called DCF's call center, a trained agent also misread the notice and gave her the wrong answer about her son's coverage, according to the court opinion.

The state later determined Chianne D.'s own coverage had been incorrectly terminated. She remained eligible for Medicaid.

Lagoa wrote: "When a trained DCF employee could read the notice and come away with the wrong answer about whose coverage was ending, the district court did not err in finding that the notice did not reasonably convey DCF's decision to its intended recipient."

State's defense rejected

Attorney Andy Bardos represented the DeSantis administration on appeal. He argued Florida needed to meet only minimum due-process requirements. During oral arguments, U.S. Circuit Judge Adalberto Jordan pushed back.

"This is pretty bad," Jordan told Bardos, according to WUSF's reporting.

Lagoa, a former DeSantis appointee to the Florida Supreme Court, told Bardos that Medicaid notices must provide "meaningful notice and the opportunity to be heard."

What happens next

The ruling affirms a permanent injunction issued by U.S. District Judge Marcia Morales Howard in the Middle District of Florida. That injunction bars the state from terminating a class member's Medicaid for financial ineligibility unless the written notice clearly states coverage will end, identifies each person affected and explains the reason.

Whether the state will seek U.S. Supreme Court review remains unclear. Any such petition would need to be filed before Gov. Ron DeSantis leaves office in early January, WUSF reported. Gov.-elect Byron Donalds' position on the litigation is also unknown.

WUSF reported that neither AHCA nor DCF responded to requests for comment on the ruling.

The National Health Law Program's senior attorney Katherine DeBriere said in a statement that the ruling carries added weight as states prepare to implement eligibility changes under the One Big Beautiful Bill Act, which changes who qualifies for Medicaid. Florida Health Justice Project attorney Lynne Hearne called the outcome overdue, saying it "took three years and extensive state resources to confirm the non-controversial proposition that Medicaid enrollees must be informed of the grounds upon which the state is ending their health care coverage."