Today, the Supreme Court issued one decision, described below,
of interest to the business community.
Medicaid—Private Right of Action—Supremacy
Clause
Armstrong v. Exceptional Child Center,
Inc., No. 14-15 (previously described in the
October 2, 2014, Docket Report)
Section 30(A) of the Medicaid Act requires that state Medicaid
plans contain procedures to ensure that reimbursement rates for
healthcare providers "are consistent with efficiency, economy,
and quality of care and are sufficient to enlist enough
providers" to meet the need for care and services in the
geographic area. 42 U.S.C. § 1396a(a)(30)(A). The statute
does not include an express right of action for Medicaid providers
to challenge a state plan for failure to comply with Section 30(A).
Today, in Armstrong v. Exceptional Child Center, Inc., No.
14-15, the Supreme Court held that the Supremacy Clause of the U.S.
Constitution does not confer an implied private right of action
allowing providers
