[JURIST] The US Supreme Court [official website] ruled Tuesday in Armstrong v. Exceptional Child Center [opinion, PDF] that the Supremacy Clause [Cornell LII backgrounder] does not grant a private right of action to file a lawsuit. The court held that Medicaid providers do not have the ability to sue for an injunction to force compliance with the Medicaid Act [text]. Ultimately, the justices determined that private medical companies could not enforce federal funding laws because Congress had not created the right to do so. This holding reversed a previous ruling by the US Court of Appeals for the Ninth Circuit [official website], which found that the Supremacy Clause granted the providers a right of action to sue and to seek injunction requiring compliance

Idaho’s Department of Health and Welfare (IDHW) [official website] reimburse the cost of habilitation services under the state’s Medicaid Plan. The case was brought by providers of habilitation services, who sued IDHW officials, claiming that the department has reimbursed them at rates below what is required by Section 30(A) of the Medicaid Act. The service providers sought an injunction under the act, which requires that “payments are consistent with efficiency, economy, and quality of care.”