Payments to Medi-Cal Prohibited Entities
Provider Type
- Physicians and Practitioners
- Participating Physician Groups (PPG)
- Hospitals
- Ancillary
As of July 4, 2025, the use of federal Medicaid funds is temporarily restricted for certain providers identified as Prohibited Entities. These restrictions apply for one year and affect both direct and indirect payments.
Additionally, the Federal District Court issued two separate Preliminary Injunctions (PIs) that modified the Temporary Restraining Order (TRO) originally issued on July 7, 2025. However, both PIs were stayed by the First Circuit Court of Appeals on September 11, 2025.
- July 21, 2025: A PI was issued but did not extend relief to California providers. The stay issued on September 11, 2025 does not alter the claim submission guidance for providers with or without PI relief.
- July 28, 2025: A second PI granted relief to all Planned Parenthood affiliates in California.
Prohibited Entities
A provider may be classified as a Prohibited Entity if they meet all of the following criteria:
- Operate as a nonprofit focused on family planning or reproductive health.
- Provide abortion services, except in cases of rape, incest, or life-threatening conditions.
- Received over $800,000 in Medicaid payments during fiscal year 2023.
Permitted activities
All Medi-Cal and Family Planning, Access, Care, and Treatment (PACT) providers, including those affected by H.R. 1, may continue to:
- Assist patients with Presumptive Eligibility for Pregnant People (PE4PP) and Family PACT enrollment.
- Accept eligible patients.
- Deliver services under current Medi-Cal rules, including the prohibition on billing patients directly.
Claims and payment guidance
For providers with PI Relief
In California, the only providers granted PI relief are all Planned Parenthood affiliates, per the July 28, 2025 PI. Continue submitting claims for all services rendered on July 4 through September 10, 2025. For services rendered on or after September 11, 2025, continue submitting claims for abortion-related services only. Do not submit claims for non-abortion service.
For providers without PI relief
Continue to submit claims only for abortion-related services rendered on or after July 4, 2025. These must be submitted separately and are reimbursed by the State General Funds. Claims must:
- Be submitted separately from other services.
- Include only abortion-related services and directly related ancillary care.
- Be reimbursed by State General Funds and are not impacted by H.R. 1.
Additional guidance
- Providers delegated for claims processing may continue processing claims for services rendered on or before July 3, 2025, for all providers, including Prohibited Entities.
- Providers delegated for claims processing may continue processing claims for providers with PI relief for services rendered on or after July 4, 2025, until further court instruction.
- Providers not classified as Prohibited Entities may continue submitting claims as usual.