Giraldo v. Agency for Health Care AdministrationAnnotate this Case
Under federal law, the Agency for Health Care Administration (AHCA) may only reach the past medical expenses portion - and not the future medical expenses portion - of a Medicaid recipient’s tort recovery to satisfy its Medicaid lien.
Florida’s Medicaid program, administered by AHCA, paid $322,222 for Juan Villa’s medical care after Villa was injured in an accident. Villa settled with an alleged tortfeasor for $1 million. AHCA calculated the presumptively appropriate amount of its lien at $321,720 and asserted a lien in that amount against Villa’s settlement. An administrative law judge affirmed AHCA’s lien amount. The First District Court of Appeal affirmed, concluding that both Florida law and the federal Medicaid Act allow AHCA to secure reimbursement for its Medicaid expenses from the portions of Villa’s third-party settlement recovery allocated to both past and future expenses. The Supreme Court quashed the decision below, holding that the federal Medicaid Act prohibits AHCA from placing a lien on the future medical expenses portions of a Medicaid beneficiary’s third-party tort recovery to satisfy its Medicaid lien.