Florida has submitted an amendment to its Managed Medical Assistance Section 1115 Research and Demonstration Waiver requesting federal approval to exempt permanently disabled Medicaid recipients from the standard 12-month eligibility redetermination cycle. The proposal seeks to prevent vulnerable individuals from losing Medicaid coverage due to clerical or procedural issues that frequently disrupt care for medically fragile populations.

The amendment was filed on November 5, 2025. The federal public comment period runs from November 21 through December 21, 2025, during which stakeholders nationwide may submit input to the Centers for Medicare & Medicaid Services (CMS).

What the Amendment Would Change

Under the proposal — titled the Eligibility Redetermination Exemption — Florida seeks to maintain continuous Medicaid eligibility for individuals who:

• Are permanently disabled; and
• Receive Medicaid-funded institutional care, hospice services, or home and community-based services under sections 393.066 or 409.978, Florida Statutes.

These individuals would remain enrolled throughout the redetermination period unless there is a material change in disability status or financial circumstances. If a change occurs, the beneficiary or caregiver must notify the state. The Department of Children and Families (DCF) could then conduct a redetermination with advance notice.

This exemption is designed to eliminate unnecessary coverage gaps, support continuity of care, and reduce administrative burdens for families and care coordinators.

Why Florida is Pursuing This Change

The Florida Legislature directed the Agency for Health Care Administration (AHCA) to submit this amendment through Senate Bill 2514 (2025), citing repeated issues with individuals who have significant disabilities losing coverage during redetermination despite no change in eligibility. The state estimates that more than 150,000 Medicaid recipients could benefit from uninterrupted coverage if approved.

Despite broad support within Florida, the federal outlook is challenging.

According to reporting from Healthcare Dive, CMS announced in July 2025 that it will no longer approve new Section 1115 demonstration waivers — nor extend existing ones — that:

• Allow continuous Medicaid eligibility beyond federal minimums, or
• Use Medicaid funds for workforce- or support-related initiatives.

This represents a major policy shift under Administrator Dr. Mehmet Oz. CMS is steering states back to minimum eligibility standards established in the Consolidated Appropriations Act of 2023 and the American Rescue Plan Act (ARPA) of 2021.

Given this direction, Florida’s proposal is unlikely to be approved, but documenting the need for continuous eligibility remains essential for advocacy and future policy opportunities.

Public Notice, Hearings & Stakeholder Input

Florida completed its state-level public notice process in October 2025, with hearings held in Tallahassee and Orlando. According to the state’s summary, feedback was overwhelmingly supportive — including from families, disability service organizations, care coordinators, and provider advocates who emphasized the critical need for uninterrupted Medicaid coverage for individuals with permanent disabilities.

The federal public comment period is open through December 21, 2025.

HCAF will be submitting comments and welcomes member input to help shape our response. Please send feedback to Kyle Simon, Senior Director of Policy, Advocacy & Communications, at ksimon@homecarefla.org by Wednesday, December 14, 2025.

Stakeholders may review the full amendment request and submit comments through the CMS public comment portal.