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Judge Rules Trump Administration Can't Cut Medicaid Reimbursements for Planned Parenthood

Kit Yona, M.A.

Article by: Kit Yona, M.A.

Legal Writer

Reviewed by Joseph Fawbush, Esq. | Last updated on

The budget bill passed by the Trump administration in 2025 didn't mention the Planned Parenthood Federation of America (PPFA) by name, but that didn't mask the crosshairs it drew on the nation’s leading provider of sexual and reproductive health care. It certainly wasn't subtle enough to get past a federal judge in Massachusetts.

On July 28, 2025, U.S. District Judge Indira Talwani made her temporary injunction against Section 71113 of the budget bill permanent, enjoining the federal government from withholding Medicaid reimbursement for services rendered by PPFA clinics. This ensures that PPFA clinics, which are non-profit 501(c)(3) organizations, will be able to continue to meet the healthcare needs of over two million women each year.

In her ruling, Judge Talwani noted that the provisions of Section 71113 seemed designed to target only high-volume providers of women's health care who also perform abortions, such as PPFA clinics. Given that the overwhelming majority of PPFA patients are well below the Federal Poverty Level (FPL), this news likely comes as a relief to many women.

It's Either 3% or 94%, Which Seems Like a Pretty Big Margin of Error

The first birth control clinic offering information and advice in the United States opened in 1916. It lasted nine days before being raided and shuttered by the police. Additional clinics began popping up during the 1920s, and in 1939, the American Birth Control League merged with the Birth Control Clinical Research Bureau to form the Birth Control Federation of America (BCFA). This would be renamed the Planned Parenthood Federation of America (PPFA) in 1942.

With more than two million patients visiting almost 600 clinics, the PPFA is the nation's largest sexual and reproductive healthcare provider. As indicated in their 2022-2003 annual report, the PPFA clinics performed more than 400,000 pap smears and breast exams, tested for and treated more than four million sexually transmitted infections (STIs), and provided more than 225 million birth control services.

The clinics also performed close to 400,000 abortions, a service that has long made them the target of conservative lawmakers. Detractors have claimed that 94% of PPFA's actions are abortions or related to abortions. PPFA has countered that the correct number is only 3%. It's not entirely clear how either number was reached, but given the statistics provided in the annual report, the actual percentage is likely somewhere on the lower end of the scale.

Since PPFA clinics are bound by the Hyde Amendment, which doesn't allow Medicaid funds to be used for an abortion except in cases of rape, incest, or when the woman's life is in danger, it's estimated that less than 1% of abortions performed by PPFA clinics are eligible to be paid for with federal funds. The overwhelming amount of Medicaid-eligible health care provided by PPFA clinics is for health issues, birth control, and sexual education.

Some have accused PPFA of increasing the number of abortions performed while reducing other services. It can be argued that this viewpoint overlooks the aftermath of Dobbs v. Jackson Women's Health. With a sizeable number of states instituting either bans or onerous requirements, many abortion providers were forced to close. PPFA clinics became the only option available for many.

The Name Isn't in the Budget, but It Might as Well Be There

Section 71113 of the budget bill doesn't name PPFA specifically, but the narrow focus of the guidelines hints at who the bill is targeting. It makes a "prohibited entity" out of a non-profit that performs any abortions that aren't in line with the Hyde Amendment and receives more than $800,000 in Medicaid reimbursements. While PPFA clinics perform any type of legal abortion, they don't use Medicaid funds to pay for them.

Citing Section 71113 as a violation of PPFA's First Amendment rights, as well as a likely unconstitutional punishment, Judge Talwani noted that the provision could be easily construed as trying to force PPFA clinics to remove abortions from their services to retain funding.

An appeal seems likely. In the meantime, the block will remain in place, allowing funds to be released to PPFA.

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