This bulletin applies to both NC Medicaid Direct and NC Medicaid Managed Care.
This bulletin replaces in full the Updated Guidance for NC Medicaid Payments to Planned Parenthood – Sept. 19, 2025 bulletin.
Overview of H.R.1 and Court Actions
H.R.1 (Pub. L. No. 119-21) was signed into law on July 4, 2025, by President Trump. H.R.1 prohibits Medicaid payments to certain prohibited entities for one year, effective July 4, 2025. This provision was temporarily blocked from implementation by a Federal District Court Judge, who issued a temporary restraining order (TRO) effective through July 21, 2025. The preliminary injunction only applied to Planned Parenthood meeting certain criteria.
On July 28, 2025, the Federal District Court Judge granted a preliminary injunction to Planned Parenthood Association of Utah, Planned Parenthood League of Massachusetts and all other members of the Planned Parenthood Federation of America, Inc., which includes the NC Planned Parenthood entities (Planned Parenthood South Atlantic).
On Sept. 11, 2025, the U.S. Court of Appeals for the First Circuit stayed both of the preliminary injunctions issued in July 2025. The stay allowed the H.R.1 provisions to take effect and Medicaid payments to be prohibited to Planned Parenthood while legal challenges continued.
On Dec. 2, 2025, a Federal District Court Judge, in a lawsuit filed by the District of Columbia and 22 States, including North Carolina (collectively the “Plaintiff States”), granted a preliminary injunction to the Plaintiff States to allow payment to entities that may be considered a “prohibited entity” under Section 71113 of H.R.1 while legal challenges continue.
Updated Payment Guidance
Pursuant to the injunction, payment will resume to any NC Medicaid-enrolled provider considered a “prohibited entity”, including Planned Parenthood, for Dates of Service (DOS) on or after Oct. 1, 2025, until further instructions have been received from the courts.
At this time, NC Medicaid-enrolled organizations with the legal name “Planned Parenthood South Atlantic” are impacted by the “prohibited entity” provision in Section 71113 of H.R.1.
- Pursuant to the preliminary injunctions entered July 2025, these providers may receive payment from NC Medicaid for services rendered with DOS prior to Sept. 10, 2025.
- Pursuant to the Sept. 11, 2025, stay of the July 2025 preliminary injunctions, no NC Medicaid payments will be made to these providers for DOS between Sept. 11, 2025, and Sept 30, 2025. NC Medicaid will reprocess and recoup any paid claims and medical home payments for DOS between Sept. 11, 2025, and Sept. 30, 2025.
- Pursuant to the Dec. 2, 2025, preliminary injunction, these providers may receive payment from NC Medicaid for services rendered for DOS on or after Oct. 1, 2025.
Ongoing Monitoring and Commitment
NC Medicaid understands that this situation is rapidly evolving and will continue to monitor any changes as it relates to this provision.
NC Medicaid is committed to maintaining access to health services for Medicaid beneficiaries while also complying with all applicable federal requirements. NC Medicaid appreciates your ongoing partnership.
Contact
NCTracks Call Center: 800-688-6696
For questions related to NC Medicaid Managed Care, contact the health plans for more information. Contact information is available on the Health Plan Contacts and Resources webpage.