Maria Isabel Giraldo v. Agency for Health Care Administration, 248 So. 3d 53

Juan L. Villa, a Florida Medicaid recipient, received $322,222.27 in Medicaid payments after a severe ATV accident and later settled with one tortfeasor for $1,000,000 while claims against others remained pending.
AHCA calculated a presumptive Medicaid lien of $321,720.16 under Fla. Stat. § 409.910(11)(f) and asserted that lien against Villa’s settlement.
At the DOAH hearing, uncontested expert testimony allocated only $13,881.79 of the settlement to past medical expenses; AHCA contended it could lien amounts allocated to future medical expenses as well.
The ALJ and the First District upheld AHCA’s full statutory-formula lien; the Second District (Willoughby) reached the opposite conclusion, creating conflict.
The Florida Supreme Court granted review to resolve whether federal Medicaid law permits a state to lien the portion of a tort recovery allocable to future medical expenses.
The Court held that under federal law AHCA may lien only the portion of a recovery allocable to past medical expenses and remanded to reduce the lien to $13,881.79 (subject to the concurrence/dissent regarding factfinding).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether AHCA may assert a lien on portions of a Medicaid recipient’s tort recovery allocated to future medical expenses	Giraldo: federal law limits AHCA to past medical expenses only; lien should be reduced to amount allocable to past expenses ($13,881.79)	AHCA: Medicaid law and Florida statute permit recovery from amounts allocated to both past and reasonably anticipated future medical expenses; statutory-formula lien stands unless rebutted	Held: Federal Medicaid Act permits lien only on amounts allocable to past medical expenses; AHCA cannot lien future medical expenses portions
Whether appellate court may decide the proper allocation to past medical expenses without remand to factfinder	Giraldo: uncontested expert evidence established $13,881.79 allocable to past medical expenses; no reasonable basis to reject it, so reduction may be ordered on appeal	AHCA/Polston J. (dissent): ALJ questioned the testimony; proper allocation is a factual issue that should be resolved by a factfinder on remand	Held: Majority ordered reduction to $13,881.79 because evidence allocating that amount to past expenses was uncontradicted and there was no reasonable basis to reject it; one justice dissented, preferring remand for factfinding

Arkansas Dep’t of Health & Human Servs. v. Ahlborn, 547 U.S. 268 (2006) (federal Medicaid law does not authorize a state to assert a lien on portions of a settlement not designated as payments for past medical care)
Wos v. E.M.A., 568 U.S. 627 (2013) (when allocation is judicially approved or stipulated, that allocation governs; where not, courts or appropriate proceedings must determine allocation)
Willoughby v. Agency for Health Care Admin., 212 So. 3d 516 (Fla. 2d DCA 2017) (state may not lien recovery portions allocable to future medical expenses)
Giraldo v. Agency for Health Care Admin., 208 So. 3d 244 (Fla. 1st DCA 2016) (First District decision below holding AHCA could recoup past and future medical expense allocations; quashed by Fla. Supreme Court)