By Sean Orr, M.D. | November 12, 2026 | Florida Doctor Magazine
On November 4, 2026, a unanimous panel of the U.S. Court of Appeals for the Eleventh Circuit held that the notices Florida used to end Medicaid coverage for income reasons did not give families constitutionally adequate notice. The published opinion in Chianne D. v. Secretary, Florida Agency for Health Care Administration (No. 26-10419) affirms a permanent injunction from U.S. District Judge Marcia Morales Howard in Jacksonville. Florida may not end a class member’s Medicaid for income unless the notice says plainly that coverage will end, names each person losing it, and shows the household size and countable income the state used. For Florida physicians, the practical point is at the front desk: some of the children, parents and pregnant patients on your schedule lost coverage through a notice a federal court has now found legally defective, and many of them do not know they can contest it. There is no physician filing deadline, but the front-desk work starts now.
The ruling belongs with the other coverage losses in our Medicare and payers 2027 guide, including the immigrant Medicaid and Medicare cutoff and the 760,000 canceled marketplace plans.
What the Court Decided
Judge Barbara Lagoa wrote the opinion for a panel that included Judges Adalberto Jordan and Robin Rosenbaum. The court agreed with the district court that “Florida’s notice system did not provide constitutionally adequate notice,” and it agreed that the notices were too vague and confusing to tell recipients what action the state intended to take. The core problem was that a family could not tell why the state had decided they earned too much. In Judge Lagoa’s words, “without knowing which premise DCF used, the recipient does not know what objection to make.”
The opinion notes that Florida redetermined eligibility for more than four million people between April 2023 and March 2024, and that in April 2024 the Department of Children and Families blocked 744,000 calls before they could reach a queue for a live agent. The named plaintiff received an 11-page notice in April 2023 covering herself and her newborn son, and the state later found her own coverage had been ended in error, according to the Florida Phoenix.
Who the Injunction Covers
The certified class is Florida Medicaid enrollees whose coverage was ended for income on or after March 31, 2023 through a notice that did not identify the individual income used or the income standard applied. Terminations for other reasons are outside the class. The Florida Trib reports that the class covers family-related Medicaid (children, pregnant women, and parents or caretakers of minors) and included nearly 500,000 people.
Under the injunction as the opinion describes it, a termination notice must state unambiguously that coverage will end, identify each person whose coverage will end, and, for an income decision, give at a minimum the household size and countable income, the eligibility category the person had been in, and the reason for any change. After the Eleventh Circuit refused to pause the injunction in April, the state had to send corrected notices or restore coverage by May 1. The Florida Trib reports that DCF and the Agency for Health Care Administration sent roughly one million corrective notices by that date and still pursued the appeal.
Why It Matters in the Exam Room
When a patient loses Medicaid without understanding why, the first place it shows up is usually not a hearing office. It shows up as a missed well-child visit, a prenatal appointment that gets canceled, or a claim denied for eligibility weeks after the service. Plaintiffs’ counsel told the Florida Trib that appeals are backlogged and that “people are not getting the coverage pending appeal that they’re entitled to.”
The ruling also sets a standard. A Florida Health Justice Project attorney told the Florida Phoenix that the decision makes this “the standard for all Medicaid termination notices.” That matters because Florida is already sending termination notices to other groups, including immigrant enrollees, and federal eligibility changes are coming in 2027.
The State’s Case and the Families’ Case
Florida argued that the district court went further than the Constitution requires and, in the Florida Trib’s summary, “unfairly forced the state to show its math.” The state also had real obligations behind the redeterminations: federal rules required Florida to recheck every enrollee after the pandemic coverage protections ended, and program integrity means people who no longer qualify should leave the rolls. Neither AHCA nor DCF responded to reporters’ requests for comment on the ruling, and it is not clear whether the state will ask the U.S. Supreme Court to review it.
The families’ position is that a person cannot challenge a mistake they cannot see. If the notice does not say what income the state counted, a parent has no way to tell whether a paycheck was double-counted or the household size was wrong. These positions fit together. Accurate eligibility checks and clear notices are not opposites, and a notice that shows the numbers makes it easier to remove people who truly no longer qualify while catching the errors before a child misses care.
What Florida Physicians and Practice Managers Should Do Now
- Verify Medicaid eligibility on the day of service and again before any scheduled procedure, delivery planning visit or specialist referral.
- Teach your front desk a short script for a patient holding a confusing termination notice: ask to see the notice, note the date printed at the top and the date coverage ends, and point the patient to the hearing instructions on the notice.
- Tell patients the timing that matters. The Florida Health Justice Project explains that a hearing request made before the end date on the notice keeps benefits in place at least until the hearing decision, and that a request can still be made up to 90 days after the date at the top of the notice. Requests can go through DCF’s online appeal form or by email to the Office of Appeal Hearings.
- Refer patients who want help to legal aid or to the Florida Health Justice Project, which brought the case with the National Health Law Program. None of this constitutes legal advice, so keep your staff’s role to pointing patients toward the notice, the hearing office and legal help rather than interpreting eligibility rules for them.
- Document what you see. A note that a patient presented with a termination notice and was given hearing information protects the patient and gives your practice a record if a claim is later denied for eligibility.
The Bigger Picture
Physicians rarely see the eligibility system, but we see what it does to continuity of care. A federal appeals court has now said that a family losing Medicaid is owed a plain explanation of why. Our practices can help make that standard real by catching coverage gaps early and sending patients to the people who can fix them. Organized medicine in Florida should also ask AHCA and DCF to show physicians what the new notices look like, so our offices can explain them to the patients who bring them in.
Frequently Asked Questions
What did the Eleventh Circuit rule about Florida Medicaid termination notices?
On November 4, 2026, the court held that Florida’s income-based Medicaid termination notices did not give constitutionally adequate notice and affirmed Judge Howard’s permanent injunction. Notices must now state that coverage will end, name each person affected, and show the household size and countable income used.
Which Florida Medicaid patients are in the class?
Enrollees whose coverage was ended for income on or after March 31, 2023 through a notice that did not identify the income used or the income limit applied. Reporting describes the class as family-related Medicaid (children, pregnant women and parents or caretakers), nearly 500,000 people.
How can a patient keep Medicaid while appealing a termination in Florida?
According to the Florida Health Justice Project, a fair hearing request made before the end date on the notice keeps benefits in place at least until the hearing decision. Requests can be made through DCF’s online hearing request form or by email to the Office of Appeal Hearings.
Does this ruling change how my practice bills Medicaid?
No. The ruling governs the notices the state sends to enrollees, not claims rules. It does make same-day eligibility checks more important, because more patients may move between coverage and no coverage while notices are corrected and hearings proceed.
Can Florida still appeal the decision?
The state may seek further review, including at the U.S. Supreme Court. As of the latest reporting, AHCA and DCF had not said whether they will.
This article was drafted with the assistance of AI writing tools, then reviewed, edited, and approved by Dr. Sean C. Orr, M.D., who holds full editorial responsibility for its content. Illustration created with AI image tools.
References
- U.S. Court of Appeals for the Eleventh Circuit, Chianne D. v. Secretary, Florida Agency for Health Care Administration, No. 26-10419 (November 4, 2026). ca11.uscourts.gov
- Sharmila Venkatasubban, “Appeals court upholds ruling that Florida’s Medicaid termination notices were unconstitutional,” Florida Trib (November 5, 2026). floridatrib.org
- Christine Sexton, “Federal appeals court finds Florida’s Medicaid termination letters insufficient,” Florida Phoenix via WLRN (November 9, 2026). wlrn.org
- Leah S. Poniatowski, “11th Cir.: Florida’s Medicaid termination notices violated due process protections,” VitalLaw Health Law Daily (November 6, 2026). vitallaw.com
- National Health Law Program, “Eleventh Circuit Update in Florida Medicaid Notice Case” (April 2, 2026). healthlaw.org
- Florida Health Justice Project, “What can I do if my DCF notice says Medicaid benefits are ending, or my Medicaid ended with no advance notice?” floridahealthjustice.org
- Florida Department of Children and Families, Office of Appeal Hearings, online public assistance hearing request. myflfamilies.com