KAHN, J.
Appellants challenge an immediate final order (IFO) issued by the Department of Insurance (Department) addressing recent amendments to section 627.6699(5)(c), Florida Statutes. Appellants are trade associations composed of health maintenance organizations (HMOs). The majority of these HMOs consist of small employer carriers within the meaning of section 627.6699 and were targeted by the IFO at issue here. We reverse because the IFO does not contain sufficient...
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