No difference.
"Significantly, in the Browning case, the Florida Supreme Court found that the right attaches, so long as "the patient has expressed his or her desires in a 'living will,' through oral declarations, or by the written designation of a proxy to make all health care decisions in these circumstances."
Well I guess the good old Florida Supreme court decided it was time to legislate from the bench. I noticed that the petitioner on this case was non other than George Felos. Man he is a busy man working so hard to get the laws changed in Florida so we can all part take of his grand euthanasia plan.