AMANDA SOTO
v.
AGENCY FOR HEALTH CARE ADMINISTRATION
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The appellate court reversed an administrative law judge's decision, holding that the appellant was entitled to a reduction in the Medicaid lien. The court found the appellant presented sufficient evidence for a pro rata reduction, which the agency failed to contest.
Yes, the ALJ erred as a matter of law. The appellant presented sufficient evidence for a pro rata reduction, and the agency failed to present evidence to the contrary.
[1] A Medicaid recipient may reduce an AHCA lien using a pro rata method to allocate settlement proceeds between past medical expenses and other damages when the recipient pr…
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Join FLexlaw to unlock all legal intelligence“Since this case was decided by the ALJ, the Florida Supreme Court and this Court have accepted the use of the pro rata method to reduce the Medicaid lien when the Medicaid recipient has presented competent, substantial, and uncontradicted evidence to support her position that only a portion of the settlement should be allocated for past medical expenses.”
Establishes the legal precedent for reducing Medicaid liens using the pro rata method.
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Join FLexlaw to unlock all legal intelligenceThe appellant sought a reduction of the Agency for Health Care Administration's (AHCA) Medicaid lien against her settlement proceeds. The administrati…
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PER CURIAM.
The appellant argues that the administrative law judge (ALJ) erred when he determined that she was not entitled to a reduction in the Agency for Health Care Administration’s (AHCA) Medicaid lien that was imposed against the proceeds from her settlement with a third-party tortfeasor. The ALJ concluded that the appellant was not entitled to a reduction because she failed to prove that her pro rata methodology was sanctioned by the Legislative mandate for the Medicaid lien to be paid in full. Since this case was decided by the ALJ, the Florida Supreme Court and this Court have accepted the use of the pro rata method to reduce the Medicaid lien when the Medicaid recipient has presented competent, substantial, and uncontradicted evidence to support her position that only a portion of the settlement should be allocated for past medical expenses.∗ Giraldo v. Agency for Health Care Admin., 248 So. 3d 53, 56 (Fla. 2018); Bryan v. State, 291 So. 3d 1033, 1036 (Fla. 1st DCA 2020); Mojica v. Agency for Health Care Admin., 285 So. 3d 393, 398 (Fla. 1st DCA 2019); Eady, 279 So. 3d at 1259.
The record shows that the appellant presented competent, substantial, and uncontradicted evidence to support the reduction of her Medicaid lien by using a pro rata method. AHCA failed to present any evidence that the appellant’s proposed pro rata methodology was inaccurate or that another method would be more appropriate to apply. For those reasons, the ALJ erred as a matter of law by concluding that the appellant failed to prove that her Medical lien should have been reduced. See Mojica, 285 So. 3d at 396−98.
Accordingly, we reverse and remand the cause to the Department of Administrative Hearings for the ALJ to reduce AHCA’s Medicaid lien to $26,641.59. REVERSED and REMANDED. B.L. THOMAS, ROBERTS, and ROWE, JJ., concur. _____________________________
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Citator
Cited By
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Bryan v. State (Fla. 1st DCA 2020)…edical expenses,” and (2) “there was no reasonable basis in the record to reject that evidence . . . .”. Thus, this Court compelled the ALJ to reduce AHCA’s lien to comport with the appellant’s pro rata methodology. Id. Moreover, in Mojica v. State, 285 So. 3d 393, 394 (Fla. 1st DCA 2019), a case that factually mirrored Giraldo and Eady, the appellant—an eight-year-old girl who suffered catastrophic brain damage as a result of medical malpractice—settled her cause of action with liable third parties for $8.8…
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Domingo v. State (Fla. 1st DCA 2020)…a portion of the settlement should be allocated for past medical expenses.∗ Giraldo v. Agency for Health Care Admin., 248 So. 3d 53, 56 (Fla. 2018); Bryan v. State, 291 So. 3d 1033, 1036 (Fla. 1st DCA 2020); Mojica v. Agency for Health Care Admin., 285 So. 3d 393, 398 (Fla. 1st DCA 2019); Eady, 279 So. 3d at 1259. In this case, the appellant presented competent, substantial, and uncontradicted evidence to support the reduction of his Medicaid lien by using a pro rata method. AHCA failed to present any evi…
Authorities Cited
- Giraldo v. Agency FOR Health Care Admin., 248 So. 3d 53 (Fla. 2018)