Health Law Daily Wrap Up, MEDICAID ELIGIBILITY—11th Cir.: Florida’s Medicaid termination notices violated due process protections, (Nov 6, 2026)

By Leah S. Poniatowski, J.D.

The district court’s injunction stands against the state to mandate adequate explanation for termination decisions.

A federal district court in Florida did not err when it determined that Florida’s agencies providing termination of Medicaid benefits notices violated the due process rights of certain enrollees because the notices did not provide adequate explanation and information for the enrollee to object to the determination, the U.S. Court of Appeals for the Eleventh Circuit ruled. The appellate panel also held that the lower court did not err when it determined the legal question central to the narrowly defined class of enrollees to affirm the lower court (Chianne D. v. Secretary, Florida Agency for Health Care Administration, No. 26-10419 (11th Cir. Nov. 4, 2026)).

Background. The state of Florida administers the Family-Related Medicaid program for low-income resident parents, caretakers, expectant parents, infants, and children via two agencies: the Florida Department of Children and Families (DCF), which determines eligibility; and the Florida Agency for Health Care Administration (AHCA), which operates as the state’s Medicaid payor. Under applicable federal law, DCF initially evaluates non-financial eligibility and then considers financial eligibility. To facilitate eligibility determinations, DCF uses a mainframe computer system, FLORIDA. When the FLORIDA system makes an ineligibility determination, DCF sends a single written notice explaining the final eligibility decision.

The federal government passed a law that suspended Medicaid eligibility reviews during the COVID-19 pandemic, which was later terminated on March 31, 2023. During the following “unwinding” period through March 2024, Florida restarted the regular eligibility reviews, impacting over four million residents.

Notice contents. In general, a notice will provide the eligibility determination for multiple public benefit programs, family members, and time periods. If the Medicaid termination is income-based, the notice will provide a statement that the benefits for the identified recipient will end on a specific date. Additionally, a standardized “Designated Reason” may be provided or a statement that the household income exceeds the Medicaid limit will be included in another section of the notice.

If a notice recipient would like more information about a benefit determination, they can contact a DCF call center to speak with an agent with access to the FLORIDA system and related data. Notice recipients may also check the MyACCESS online portal, public Medicaid materials, or a DCF Family Resource Center. Further, a hearing may be requested to challenge a termination determination.

“Unwinding” notices. A group of enrollees who received termination notices during the “unwinding” period took issue with the notices that they had received. Among their complaints, they showed that the multiple-page notices provided contradictory information as to the eligibility of their newborn children, statements that a household income was “too high” without disclosing what data was used to make the determination, incorrect eligibility categorization, and other errors that were later corrected to restore program enrollment.

Procedural history. This group of enrollees filed a class action lawsuit against the Secretary of the AHCA and the Secretary of DCF, alleging that the Due Process Clause and the Medicaid Act were violated by the deficient termination notices. The federal district court held a bench trial and dismissed the Medicaid Act cause of action but determined that the enrollee’s due process rights had been violated, granting both a declaratory judgment in their favor and a permanent injunction mandating that the agencies provide adequate reasons with a termination decision (see Florida to face class action challenging lawfulness of Medicaid termination notices, Apr. 26, 2024). The lower court found that in addition to the “exceedingly confusing and contradictory” notices that left enrollees unable to understand the state’s reasons and intent for the termination, the state’s other resources did not resolve the problem.

Accordingly, the permanent injunction barred Florida from terminating a class member’s Medicaid for financial ineligibility “unless the written notice (i) unambiguously states that Medicaid coverage will end; (ii) identifies each person whose coverage will end; and (iii) explains the reason for the decision as to that person.” Additionally, income-based terminations must include, “at a minimum,” the household size and countable income in order to identify the enrollee’s eligibility category, and the explanation of changes. Florida filed the present appeal.

Due process. Under U.S. Supreme Court precedent, due process protections exist when a government is in the position to deprive an individual of a protect interest, which include termination of public benefits. Critical to due process is providing the individual with timely and adequate notice with the reasons for the determination. In the case at bar, the appellate panel agreed with the lower court that Florida’s agencies did not provide unambiguous explanation for the termination of Medicaid benefits, either in the written termination notice or via other sources.

Specifically, the appellate panel observed that one of the termination notices not only provided contradictory information about coverage for a newborn, but the DCF agent reading the same notice could not provide the correct coverage explanation. Additionally, the notices did not provide sufficient information for the enrollees to confirm whether an income-based eligibility decision was correct, thus precluding the enrollee from adequately objecting to a negative decision.

The panel also determined that “under all the circumstances” the totality of the notice system was inadequate to inform program enrollees. In addition to the above-mentioned interaction with a DCF agent, in April 2024 alone, 744,000 calls to the agency were blocked before they were queued to be picked up by a live agent, and roughly a third of the calls that were queued ended before an agent picked up. The other means to support enrollee issue resolution were similarly inadequate to provide sufficient information to the enrollee. Because the lower court did not err when making its ruling, its determination was affirmed.

Rule 23. Under the federal procedural rules governing class actions, Rule 23(c)(1)(B) requires a certification order to “define the class and the class claims, issues, or defenses.” Florida argued that the lower court only certified a challenge to the information not included from the termination notices yet determined that there was a “structural claim” about Florida’s notice communication that was not certified. The appellate panel disagreed that the lower court went beyond the certified class claim.

First, the lower court limited the class to Medicaid enrollees who received income-based termination notices which did not identify the income used in the eligibility determination or the income standard applied. The lower court also certified a subclass for whom no “Designated Reason” was provided or a non-income based “Designated Reason” was provided. Second, the lower court identified the central question to be whether Florida’s notices were “reasonably calculated to apprise intended recipients, as a whole, of their rights,” thus reflecting the challenge to the reasonableness of Florida’s notices per governing precedent.

The panel explained that despite the variances in the notice letters to this specific group of enrollees, ultimately the issue common to the class was whether Florida told them what it was doing and why. The injunction was not over broad or improperly saddle the state with details of how to design the notices or change the “structure.” The minimums put forth by the lower court reflect the standards in controlling Supreme Court case law. Accordingly, the lower court did not err when it issued the injunction. Therefore, the lower court’s ruling was affirmed.

The case is No. 26-10419.

Judge: Lagoa, B.

Attorneys: Sarah Grusin (National Health Law Program) for Chianne D. Andy Bardos (Shutts & Bowen, LLP) for Secretary, Florida Agency for Health Care Administration.

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