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ADA Statement: Supreme Court Ruling on Armstrong v. Exceptional Child Care Center

April 07, 2015

Contact Information:
Rhys Saunders

The American Dental Association (ADA) is disappointed in the recent ruling by the United States Supreme Court in Armstrong v. Exceptional Child Care Center that health care providers do not have standing to bring a lawsuit challenging inadequate Medicaid reimbursement rates based on a state’s failure to meet Medicaid’s equal access requirement.

“This ruling creates yet another hurdle for advocates of Medicaid reform,” said ADA President Dr. Maxine Feinberg. “Dentists and physicians continue to vigorously advocate for improvements to state Medicaid programs. Oral health is vital to overall health, especially for chronic diseases such as diabetes, and yet most states allocate just two percent or less of their Medicaid budgets for dental services. This Supreme Court decision results in one less recourse for health care providers seeking to hold states accountable to federal mandates.”

The case arose when a health care provider in Idaho sought a federal court injunction to require the state to increase its rates consistent with the stated intent of the Medicaid Act to provide access to quality care and medical services, “at least to the extent that such care and services are available to the general public in the [relevant] geographic area.”  

The ADA, American Medical Association, American Academy of Pediatrics, American Academy of Family Physicians, and other health care associations had filed an amicus brief in support of the health care provider, arguing that Supremacy Clause of the United States Constitution, the clause making federal law the supreme law of the land, created a private right of action that permitted the plaintiffs to seek the requested relief. The Court ruled, however, that the plaintiffs did not have standing to pursue their action and held that the only “corrective” remedy provided under the Medicaid Act was the power of the Secretary of Health and Human Services to withhold federal Medicaid money from Idaho.

The broad language used by the Court on the private remedy issue raises the question as to whether Medicaid patients will still have the right to challenge state underfunding of Medicaid programs.

About the ADA

The not-for-profit ADA is the nation's largest dental association, representing 161,000 dentist members. The premier source of oral health information, the ADA has advocated for the public's health and promoted the art and science of dentistry since 1859. The ADA's state-of-the-art research facilities develop and test dental products and materials that have advanced the practice of dentistry and made the patient experience more positive. The ADA Seal of Acceptance long has been a valuable and respected guide to consumer dental care products. The monthly The Journal of the American Dental Association (JADA) is the ADA's flagship publication and the best-read scientific journal in dentistry. For more information about the ADA, visit For more information on oral health, including prevention, care and treatment of dental disease, visit the ADA's consumer website