In 2018, the governor of South Carolina directed (PDF) the state’s Department of Health and Human Services to prohibit clinics offering abortion services from participating in the state’s Medicaid program. Planned Parenthood and a Medicaid beneficiary sued in response.

In the next few weeks, the US Supreme Court will rule on the case Medina v. Planned Parenthood South Atlantic, determining if Medicaid beneficiaries can sue to enforce the “free choice of provider” provision. The court’s decision could greatly restrict access to affordable reproductive care—including breast exams, pregnancy testing, and sexually transmitted infection (STI) testing—in South Carolina and beyond.

Preventing Medicaid beneficiaries from suing to enforce the free choice of provider provision could allow states to exclude Planned Parenthood clinics from Medicaid

At the heart of the Medina v. Planned Parenthood South Atlantic case is the right of Medicaid beneficiaries to seek care from any qualified organization, known as the free choice of provider provision. Because family planning services are a mandatory benefit within the Medicaid program and are covered without copays, beneficiaries are entitled to use qualified Medicaid providers at Planned Parenthood and other clinics that offer abortion services for family planning care, even if they aren’t in network.

Currently, 2 in 10 US women have health insurance coverage through Medicaid, and Planned Parenthood reports serving more than 2 million (PDF) patients annually, nearly 70 percent (PDF) of whom live with incomes at or below 150 percent of the federal poverty level. In total, Planned Parenthood centers serve 1 in 10 Medicaid beneficiaries of reproductive age.

The vast majority of Medicaid-covered services provided by Planned Parenthood clinics are contraceptive services, STI testing and treatment, and other gynecological care, such as pregnancy testing, Pap smears, and breast exams. States have some discretion in the scope of family planning services covered by Medicaid, though federal law already prohibits the use of federal Medicaid funds to pay for abortion under the Hyde Amendment.

A decision in favor of South Carolina would allow the state to exclude clinics that provide abortion services, including Planned Parenthood, from their Medicaid program. This move could restrict access to care for Medicaid beneficiaries and other people with low incomes in the state if clinics reduce operations or close.

It could also lead to other states following suit—joining the recent trend of “copycat” legislative action like that mirroring Texas’s six-week abortion ban and Idaho’s “abortion trafficking” law. This would curtail access to reproductive health care on a larger scale.

This will be the first Supreme Court ruling on this issue, though federal courts have previously allowed Texas (PDF) and Arkansas (PDF) to exclude Planned Parenthood from receiving Medicaid funds, which destabilized the reproductive health landscape in those states. After Texas excluded Planned Parenthood providers from its state-funded family planning program in 2013, the number of claims for contraceptive services decreased. Access to care further eroded after the state terminated Planned Parenthood affiliates from the full-benefit Medicaid program in 2021. Enrollees reported difficulties finding a new provider, instead delaying or forgoing reproductive care.

If the Supreme Court rules in favor of South Carolina, these effects could be amplified, as additional states could legally exclude Planned Parenthood from Medicaid, leading to fewer clinics, longer wait times, and decreased contraceptive options. More broadly, states would have discretion to exclude providers because of political opposition.

Other current federal actions further threaten the nation’s reproductive health landscape

Recent federal actions that have diminished reproductive care could amplify the ramifications of the Supreme Court’s decision. In March 2025, the US Department of Health and Human Services withheld tens of millions of dollars in Title X funding from grantees in South Carolina and 22 other states, including all Planned Parenthood grantees. The agency has continued to withhold these funds while it investigates whether recipients are in compliance with new actions curtailing diversity efforts. 

The Title X Family Planning Program supports affordable family planning and preventive health services for more than 2 million (PDF) patients annually. As the freeze continues, patients across the country could lose access to services, with the Planned Parenthood North Central States affiliate already announcing planned clinic closures.

Additionally, the budget reconciliation bill passed by the US House of Representatives includes a provision that could restrict access to family planning services for Medicaid beneficiaries nationwide. The provision would prohibit Medicaid funding of care provided by essential community providers that are primarily engaged in family planning services or reproductive services, that provide abortions other than for Hyde Amendment exceptions, and that received $1 million or more in federal funding in 2024. The Congressional Budget Office estimates this provision would increase the federal deficit by $261 million over 10 years, likely because of the higher costs of delayed care (such as emergency department visits) and an increase in Medicaid spending on births, as happened in Texas.

Together, Title X and Medicaid account for 85 percent of public spending on family planning services. If these programs are cut at the national level, Planned Parenthood and other affected reproductive health providers will face financial constraints that could reduce their capacity to provide care. Evidence suggests other safety net providers, such as federally qualified health centers and health departments, are unable to absorb the loss of Planned Parenthood clinics, putting additional strain on reproductive health systems.

At a time when access to affordable reproductive care is already in jeopardy, a Supreme Court ruling in favor of South Carolina could amplify the risks. As such, patients across the country—both covered by Medicaid and not—could face extremely limited access to the full suite of reproductive care.