On June 26, 2025, the Supreme Court ruled that Medicaid providers and beneficiaries lack the ability to enforce the Medicaid Act’s “any‑qualified‑provider” clause in federal court. In Medina v. Planned Parenthood, the Court considered whether Medicaid beneficiaries—or providers like Planned Parenthood—have a right under § 1983 to directly sue states that disqualify them from their Medicaid provider network on the basis that it violates Title XIX. The Supreme Court confirmed that the sole remedy for alleged violations of this Medicaid statute (and, conceivably, most Medicaid statutes) was the withdrawal of federal funds, not private enforcement, leaving providers with limited recourse against state actors.
The Challenged Actions
In 2018, South Carolina excluded Planned Parenthood South Atlantic (“Planned Parenthood”) from its Medicaid provider network on the basis that, in its view, such participation would result in public funds being used for abortion services (in purported violation of state law). The Plaintiff contended that such restrictions violated the “any‑qualified‑provider” clause of the Medicaid Act (§ 1396a(a)(23)(A)), which requires states to grant Medicaid beneficiaries access to “any provider” who is “qualified to perform” the services sought by the beneficiary and who “undertakes to provide” it.
The Plaintiff patient argued that the “any-qualified-provider” clause conferred a tangible, private right for the Plaintiff to see any provider she chose. She proceeded under 42 U.S.C. § 1983 (commonly referred to as § 1983), that authorizes individuals (such as a patient or a provider) to sue anyone who, “under color of state law,” deprives the individual of “rights, privileges, or immunities secured by the Constitution and laws” of the United States. The Plaintiff patient sought to use § 1983 to enforce the federal Medicaid law against South Carolina and thus require South Carolina to permit Planned Parenthood access to its Medicaid network. The District Court and the Fourth Circuit both agreed with the Plaintiff.
Writing for a five-justice majority, Justice Neil Gorsuch resolved a split among the federal Courts of Appeals as to whether the “any-qualified provider” clause of § 1396a(a)(23)(A) gives Medicaid beneficiaries and providers the right to enforce its provisions against state recipients of federal Medicaid funding.
Section 1983 &The Spending Clause
As noted, 42 U.S.C. § 1983 permits private plaintiffs to sue individuals who deprive any citizen “of any rights, privileges, or immunities secured by the Constitution and laws.” Justice Gorsuch’s majority opinion emphasized that not all federal statutes confer a private right of action under § 1983; instead, § 1983 rights attach only to those provisions with “clear and unambiguous” rights-creating language. As such, § 1983 provides a cause of action “only for the deprivation of ‘rights, privileges, or immunities,’ not ‘benefits’ or ‘interests.”’
Moreover, the Court expressed heightened scrutiny to the question of whether § 1983 applies to laws premised on the Constitution’s Spending Clause (like Medicaid). According to the Court, Congressional authority under the Spending Clause—unlike express Constitutional provisions authorizing Congressional actions (like to regulate commerce or combat piracy)—is not explicit. Instead, it is inferred through the Constitutional grant of authority to “provide for the common Defense and general Welfare.”
Analogizing the relationship between states and the federal government as akin to a contractual one when the spending powers are exercised, the Court reasoned that the Spending Clause allows Congress to offer funds to states that agree to certain conditions. The Court determined that those conditions must be clear: when the state accepts those funds, it must be aware of, and intend to, “answer private §1983 enforcement suits.” Continuing the contractual analogy, when there is a breach of a statutory requirement under legislation adopted pursuant to the Spending Clause, the typical remedy is “not a private suit . . . but rather action by the Federal Government to terminate funds to the State.” Therefore, the Court emphasized that spending-power legislation cannot provide the basis for a § 1983 action unless Congress “speaks with a clear voice, and manifests an unambiguous intent to confer individual rights.”
The “Any-Qualified Provider” Statute
Proceeding under this backdrop, the Court looked for an express “right” in the “any-qualified-provider” portion of the Medicaid law such that it would put a state that accepts Medicaid funds on notice that violation of its provisions would open itself up to private suit for Medicaid violations. First, the Court looked to its 2023 decision in Health & Hospital Corp. of Marion County v. Talevski, 143 S. Ct. 1444 (2023) as supplying the “only reliable yardstick against which to measure whether spending-power legislation confers a privately enforceable right.”
Talevski looked at the Federal Nursing Home Reform Act (FNHRA), which obliged nursing-home facilities to protect residents’ “right to be free from” unnecessary “physical or chemical restraints.” 42 U. S. C. §1396r(c)(1)(A)(ii) (emphasis added). Thus, because the FNHRA statute referred (and arguably, conferred) to a “right” to nursing home residents, those residents could utilize § 1983 to enforce that right.
In contrast, the Court reasoned that the “any-qualified-provider” statute lacked such right-conferring language. Specifically, its language requires state Medicaid programs to “provide that . . . any individual eligible for medical assistance (including drugs) may obtain such assistance from any institution, agency, community pharmacy, or person, qualified to perform the service or services required . . . who undertakes to provide him such services.” The Court reasoned that this language spoke only to a state’s requirements for participation in Medicaid, not any rights of Medicaid beneficiaries. Thus, there was no “clear and unambiguous ‘rights-creating language’” in the statute, and so § 1983 enforcement remained unavailable.
Justice Thomas provided a concurring opinion, advocating for further scrutiny of the scope of § 1983. In dissent, Justices Sotomayor, Kagan, and Jackson argued that the “any-qualified-provider” statute protected patient rights, and therefore a denial of standing could lead to “tangible harm to real people.”
Conclusion
The Court’s decision thus curtails a beneficiary’s (or provider’s) ability to take direct actions to enforce the “any-qualified-provider” statute (and, by extension, other Medicaid requirements), leaving private parties to rely on the federal executive branch to employ the remedy of withdrawal of federal funds in appropriate cases. The Court’s decision weakens the ability of beneficiaries and providers to challenge what they see as a state’s dereliction of its statutory obligations for the receipt of Medicaid funds.
