Federal Appeals Court Grills Florida Over Medicaid Termination Process

A three-judge federal appeals panel on Wednesday sharply questioned a Florida attorney over how the state terminated people from Medicaid after the COVID-19 pandemic, with one judge calling the state's approach "pretty bad." The hearing at the U.S. Court of Appeals for the 11th Circuit suggests the DeSantis administration may face an uphill battle defending a process that resulted in hundreds of thousands of Floridians losing health coverage.

The case, originally filed in Jacksonville federal court in 2023, challenges how Florida's Department of Children and Families conducted what's known as Medicaid "unwinding" — the process of redetermining eligibility after pandemic-era protections ended. For Northeast Florida residents, many of whom receive Medicaid coverage through the Jacksonville-based regional DCF office, the case could determine whether people who lost benefits improperly must be reinstated and whether the state must improve how it communicates with beneficiaries.

What's happening

Florida began its Medicaid unwinding process on April 1, 2023, after federal pandemic protections expired on March 31, 2023. Over the following year, the Department of Children and Families redetermined the eligibility of more than 4 million people statewide. The lawsuit was filed in U.S. District Court in Jacksonville in 2023 by attorneys for the Florida Health Justice Project and the National Health Law Program on behalf of people who lost benefits.

U.S. District Judge Monica Morales Howard certified the case as a class action in 2024 and issued a 273-page ruling in 2025 finding that termination letters sent by the state were "vague, confusing and often incorrect and misleading" in violation of federal law. Florida appealed that decision to the 11th Circuit, where a three-judge panel heard oral arguments on Wednesday.

During the hearing, Andy Bardos, the attorney representing state health care agencies, argued Florida only needed to meet minimum due-process requirements in its termination notices: notification of the intended action, the effective date, and a statement of the reason. When U.S. Circuit Judge Adalberto Jordan asked "With nothing else?" Bardos replied, "We think that's the minimum requirement of due process."

All three judges on the panel — Jordan, Barbara Lagoa, and Robin Rosenbaum — expressed skepticism about the state's position. Jordan noted the state could have included information directing people to resources where they could check their eligibility status or see exactly how much their income exceeded qualifying thresholds. "This is pretty bad," Jordan said of the state's approach.

Impact on health care access for Jacksonville-area residents

The outcome of this case will directly affect thousands of Duval County residents and many more across Northeast Florida who lost Medicaid coverage during the unwinding process. Medicaid serves as the health care safety net for low-income families, children, pregnant women, elderly residents, and people with disabilities. In a region where household incomes generally lag state and national averages in many neighborhoods, particularly in urban Jacksonville, Medicaid coverage often determines whether families can access routine medical care, fill prescriptions, or manage chronic conditions.

When beneficiaries lose coverage improperly — meaning they were actually still eligible but were terminated due to confusing paperwork or inadequate notice — they may go months without care while trying to appeal or reapply. For families with children who depend on regular checkups and immunizations, or for individuals managing diabetes, heart disease, or other ongoing conditions, gaps in coverage can lead to emergency-room visits that strain both hospital systems and families' finances. Baptist Health, UF Health Jacksonville, and Ascension St. Vincent's — the region's major hospital systems — all provide significant charity care and see higher uncompensated-care costs when Medicaid enrollment drops.

If the appeals court rules against Florida, beneficiaries who were improperly terminated could be reinstated with coverage backdated to when they lost benefits. This would allow them to resolve outstanding medical bills and resume care. The ruling could also force the state to redesign its termination notices to include specific information about why someone is being deemed ineligible — such as the exact income figures the state used — making it possible for people to identify and correct errors before losing coverage.

What the legal dispute reveals about due process

The judges' questioning Wednesday centered on a fundamental question: what does meaningful due process require when the government terminates a benefit? Judge Barbara Lagoa, a former DeSantis appointee to the Florida Supreme Court, pressed Bardos on how recipients could challenge a termination if they don't know what information the state used to determine they're ineligible.

"If you don't tell me what the basis is of the income determination that you've made, what you believe is the income, then how would I know what to challenge?" Lagoa asked. She drew an analogy to court proceedings: "I don't think you would like a trial judge to issue an order just telling you 'denied' and not tell you the basis. Correct? Because you wouldn't be able to have meaningful appellate review."

Judge Robin Rosenbaum questioned why the state wouldn't simply provide the data it used in making eligibility determinations. "What is the whole point of hiding this information?" she asked. The implication is that if the state has already gathered income or household data to make a decision, including that information in the termination notice would be straightforward and would allow recipients to spot errors — such as outdated wage information or failure to account for dependents — before their coverage ends.

Under federal Medicaid law, states must provide beneficiaries with adequate notice and a meaningful opportunity to be heard before terminating benefits. The question before the 11th Circuit is whether Florida's bare-bones notices — which stated someone was losing eligibility but often didn't explain what income or household information led to that conclusion — meet that standard. The district court found they did not; the state argues they satisfy minimum constitutional requirements even if they could have been more detailed.

How Medicaid unwinding unfolded after the pandemic

Medicaid is a joint state-federal program. During the COVID-19 pandemic, Congress increased the federal government's contribution by 6.2 percentage points in exchange for states agreeing not to disenroll anyone during the public health emergency. This "continuous coverage" requirement kept enrollment high and ensured people didn't lose health insurance during a health crisis.

Congress set March 31, 2023, as the end date for continuous coverage, allowing states to resume normal eligibility checks starting April 1, 2023. States were expected to work through backlogs of eligibility reviews — in Florida's case, more than 4 million people whose circumstances may have changed over three years. The process was bound to be complex: people's incomes, household sizes, and addresses often shift, and many beneficiaries had not submitted updated paperwork in years because they weren't required to during the pandemic.

Critics of Florida's process, including the plaintiffs in the lawsuit, argue the state moved too quickly and sent confusing notices that led eligible people to lose coverage. Common problems included letters that didn't clearly explain why someone was being terminated, didn't provide the specific data the state relied on, or were sent to outdated addresses. In some cases, families lost coverage for procedural reasons — such as not returning a renewal form — even though they remained income-eligible, because the notices didn't make clear what was needed or provided insufficient time to respond.

Nationally, the Medicaid unwinding resulted in millions of people losing coverage, with advocates and federal officials raising concerns that many disenrollments were for procedural reasons rather than actual ineligibility. Florida's process became one of the most closely watched, in part because of the state's large Medicaid population and because the lawsuit filed in Jacksonville became a vehicle for challenging notice practices that advocacy groups said violated federal law.

What happens next

The 11th Circuit panel will issue a written ruling in the coming weeks or months. There is no set timeline for when a decision will be released. If the court upholds the lower court's ruling against the state, Florida would likely be required to improve its termination notices going forward and could be ordered to identify and reinstate people who were improperly disenrolled. The state could also seek further review by requesting the full 11th Circuit to rehear the case or by appealing to the U.S. Supreme Court.

If the appeals court reverses the district court and sides with Florida, the lawsuit would likely end unless the plaintiffs seek Supreme Court review. In that scenario, the state's current notice practices would stand, and beneficiaries would continue to receive termination letters without detailed explanations of the eligibility determinations.

For beneficiaries in Northeast Florida who believe they were improperly terminated, legal aid organizations including Jacksonville Area Legal Aid and the Florida Health Justice Project can provide assistance with Medicaid appeals. The Department of Children and Families also operates a fair-hearing process where individuals can contest terminations, though advocates argue that process is difficult to navigate without the detailed information the lawsuit seeks to require in notices.

The case is being closely watched by Medicaid advocates and state officials nationwide, as multiple states face similar legal challenges over their post-pandemic unwinding processes. A ruling against Florida could set a precedent requiring more detailed and transparent notices across the 11th Circuit's jurisdiction, which includes Florida, Georgia, and Alabama. For the tens of thousands of Northeast Florida families who rely on Medicaid for health coverage, the outcome will determine whether they receive clear, actionable information if the state decides to end their benefits — or whether they must navigate a bureaucratic maze to understand and challenge those decisions.