Florida Judge Allows Class Action Lawsuit to Proceed Over Allegedly Flawed Medicaid Terminations

A federal judge has delivered a blow to Florida's Medicaid termination process, allowing a class action lawsuit to proceed on behalf of beneficiaries who claim the state improperly dropped them from the program after the COVID-19 public health emergency ended.

Lawsuit challenges notice and due process

The lawsuit, filed in August 2023, alleges that Florida failed to provide adequate notice to Medicaid recipients before terminating their coverage. Attorneys for the beneficiaries argue these flawed notices violated their clients' due process rights and federal Medicaid law. The lawsuit seeks to halt the use of the current termination notices and reinstate coverage for those who received inadequate information.

Judge rejects state's arguments

Florida attempted to dismiss the case as a class action, arguing that individual circumstances among beneficiaries made a single lawsuit impractical. However, the judge disagreed. The court acknowledged the potential for inadequate notice across a significant number of cases, justifying the class action format.

“In this case, it is undisputed that plaintiffs have a constitutionally protected property interest in their Medicaid benefits, and that they were deprived of that interest when the state terminated those benefits,” wrote Howard. “Thus, the issue in resolving this claim will be whether the state provided constitutionally-inadequate process.”

Focus on notice adequacy for income ineligibility

The judge narrowed the scope of the class action to focus on beneficiaries who received notices citing income ineligibility. The upcoming trial will determine whether these notices provided sufficient details about income calculations and specific reasons for termination. 

Notices lacking this information could be deemed inadequate, potentially forcing Florida to revise them and reinstate coverage for those wrongly terminated.

“The record reflects that all termination notices based on income contain uniform omissions such as the lack of individualized income information and income standards,” Howard wrote. “As such, the court will certify a single class to resolve the issue of whether termination notices which lack this information are adequate to satisfy the requirements of due process and the Medicaid Act when the enrollee is found ineligible based on income.”

Background on Medicaid changes

• The federal COVID-19 public health emergency (declared January 2020) barred states from removing people from Medicaid.

• Florida's Medicaid enrollment surged during this period, growing from 3.8 million to nearly 5.8 million beneficiaries.

• With the emergency's conclusion, Florida began reevaluating eligibility, leading to a drop in enrollment to 4.675 million by March 2024.

This court order paves the way for a trial on the adequacy of Florida's Medicaid termination notices. If the court finds the notices lacking, the state may be required to revise them and potentially reinstate coverage for those improperly terminated. The outcome could impact a significant number of former beneficiaries and holds implications for other states that undertook similar reevaluations after the pandemic.

The plaintiffs are represented by the Florida Health Justice Project and the National Health Law Program.

The Florida Medicaid termination class action lawsuit is Chianne et al v. Jason Weida, in his official capacity as Secretary for the Florida Agency for Health Care Administration et al, Case No. 3:23-cv-985, in the U.S District Court for the Middle District of Florida, Jacksonville Division.