U.S. Supreme Court

Health providers can't sue Idaho officials over Medicaid rates, Supreme Court says

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Providers of in-home heath care may not sue Idaho officials for paying rates for Medicaid patients that allegedly fall short of federal requirements, the U.S. Supreme Court ruled on Tuesday.

Justice Antonin Scalia wrote the majority opinion, (PDF) finding that there is no implied right of action in the supremacy clause and no authorization to sue in the federal Medicaid law.

The ability to sue to enjoin unconstitutional actions by state and federal officers “is a judge-made remedy,” Scalia wrote, “and we have never held or even suggested that, in its application to state officers, it rests upon an implied right of action contained in the supremacy clause.”

The four dissenters agreed that the supremacy clause does not imply a right of action, but argued that the health-care providers could sue in equity because Congress had not shown an intent to bar such suits.

A January story that previewed the case by Bloomberg Business said low Medicaid rates are an increasing problem for health-care providers because the Obama administration’s health-care law increased Medicaid eligibility.

The case is Armstrong v. Exceptional Child Center Inc.

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