Lexology October 20, 2025
Recent weeks and months have witnessed several Medicaid developments that may significantly impact Medicaid funding across the country. Not all of these developments are related to the Medicaid-related provisions of H.R. 1 (Public Law 119-21 (July 4, 2025), otherwise known as the “One Big Beautiful Bill”). This article summarizes three developments that are unrelated to H.R. 1:
- U.S. Fourth Circuit Court of Appeals (“Fourth Circuit”) remands intergovernmental transfer (“IGT”) funding case back to the Centers for Medicare & Medicaid Funding (“CMS”) (but does not vacate CMS’s IGT funding decision).
- The U.S. Second Circuit Court of Appeals (“Second Circuit”) holds that a provider class for a state-directed payment program must be based on a shared identifiable characteristic that “plausibly furthers...
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