Federal Appeals Judges Question Florida Medicaid Disenrollment Notices Following Post-Pandemic Unwinding

NewsWK — Federal appellate judges voiced sharp skepticism this week regarding the clarity and fairness of Medicaid termination notices sent to state residents following the end of federal pandemic-era coverage rules. The legal challenge, which affects hundreds of thousands of low-income Floridians who lost safety-net healthcare benefits during the post-COVID state review process, has reached the U.S. Court of Appeals for the 11th Circuit in Atlanta after state officials appealed a lower court decision.

During oral arguments, a three-judge panel closely examined the state’s administrative procedures. Representatives for the state argued that state agencies had fulfilled baseline constitutional requirements by informing recipients of an impending change, the effective date, and a basic rationale. However, judges across the panel questioned whether the brief notices provided citizens with sufficient detail to understand or challenge eligibility decisions.

Why it matters here

For families and healthcare providers across Northwest Florida—including Escambia and Santa Rosa counties—administrative transparency in state social safety-net programs is a critical matter of public accountability and government efficiency. Clear communication from state agencies ensures that eligible residents receive the coverage provided under state guidelines without being improperly dropped due to paperwork confusion or system errors.

Local healthcare systems, including Ascension Sacred Heart, Baptist Health Care, and community health centers operating throughout Pensacola, West Pensacola, Brent, Ferry Pass, and Milton, frequently absorb the cost of uncompensated care when patients inadvertently lose coverage without clear explanation. Conversely, maintaining accurate beneficiary rolls protects Florida taxpayers by ensuring state and federal funds are spent strictly in accordance with statutory eligibility thresholds.

Judges challenge defense of minimalist notices

The appeal stems from a federal class-action lawsuit challenging how the Florida Department of Children and Families managed the mass redetermination of benefits following the expiration of emergency federal rules. Defense counsel Andy Bardos, representing state health agencies, argued before the panel that state notifications met essential constitutional standards by providing fundamental notice and an opportunity to respond.

Appellate judges pushed back on that stance, asserting that due process requires meaningful disclosure of the facts used to reach a decision. U.S. Circuit Judge Barbara Lagoa, previously appointed by Gov. Ron DeSantis to the Florida Supreme Court before joining the federal bench, emphasized that citizens cannot reasonably contest an administrative decision if the state does not reveal the specific calculations or criteria used.

“You cannot be heard if you don’t know what you’re objecting to,” Lagoa told the state’s attorney during the hearing, drawing an analogy to judicial rulings that must state their legal grounds to allow meaningful appeal.

U.S. Circuit Judge Adalberto Jordan noted that state notices omitted basic wage and household calculations that would help individuals verify whether their eligibility determinations were correct, remarking that the lack of detailed guidance was problematic. Meanwhile, U.S. Circuit Judge Robin Rosenbaum raised questions regarding why the state would withhold the underlying factual determinations used to deny ongoing coverage.

Background: The post-pandemic Medicaid unwinding

The conflict traces back to federal COVID-19 relief legislation passed during the early stages of the public health emergency. Under those provisions, the federal government provided states with a 6.2 percentage point increase in Medicaid matching funds on the condition that states maintain continuous enrollment for existing beneficiaries throughout the emergency period.

When Congress authorized the end of continuous enrollment effective March 31, 2023, states across the country began the process known as “unwinding”—revisiting beneficiary files to ensure participants met statutory income and asset limits under normal law. Florida launched its redetermination process on April 1, 2023, reviewing eligibility for more than 4 million beneficiaries across the state.

In 2023, public interest legal groups filed a federal class-action lawsuit in Jacksonville on behalf of affected residents, claiming the state utilized flawed automated systems and issued overly ambiguous notices that left citizens unable to correct factual errors. In 2025, U.S. District Judge Marcia Morales Howard issued a comprehensive 273-page ruling concluding that the state’s termination letters failed to comply with federal statutory standards and constitutional due process because they were overly vague and difficult for ordinary citizens to navigate.

The state subsequently appealed to the 11th Circuit, arguing that its notice framework complied with historical due process minimums. A decision from the three-judge panel is expected in the coming months as the court deliberates on whether state agencies must issue detailed administrative explanations when adjusting beneficiary eligibility.