This is the first in a series of blog posts designed to provide a deeper dive into the provisions of the 2025 Reconciliation Law (Informally called the One Big Beautiful Bill Act). This installment discusses the impact of the law on reproductive rights and gender affirming care. See the note at the end of this post for a listing of further parts.

The 2025 Reconciliation Law (informally known as the “One Big Beautiful Bill Act”), signed into law on July 4, 2025 transformed dramatically from the version that was introduced in the House Rules Committee’s 22-hour meeting on May 21-22. Between that committee meeting and the law’s eventual signing ceremony, nearly all of the restrictions on abortion care and gender-affirming care were removed. What remains is a Medicaid funding provision designed to defund health care providers who provide family planning and related services. Shortly after the law’s passage, even the remaining provision quickly faced legal challenge, with a federal judge blocking its enforcement.

In this post, we explore the law, from inception to enactment, and examine how what remains will impact reproductive health care going forward.

The House version included broader restrictions

The version of the bill that came out of the House Rules Committee was approved by a slim majority  and included what Democratic Rules Committee member Teresa Leger-Fernandez (D. New Mexico) described as an attempt by her Republican colleagues to codify a national abortion ban. (See her comments at 9:14:00 of the video).

Leger-Fernandez was describing one specific portion in the bill, H.R. 1 (House Engrossed Version from May 22, 2025), which sought to prohibit the use of any federal funds to make cost-sharing reduction payments to any qualified health plan providing coverage for abortion. In other words, this provision would have provided a very strong incentive to certain health plans to stop providing insurance coverage for abortion care. The provision included few narrow exceptions to save the life of the pregnant woman and in cases of rape or incest.

The bill also would have prohibited Medicaid and the Children’s Health Insurance Program (“CHIP”) from reimbursing providers for surgical procedures or drugs for the purpose of gender transition. The provision included an exception for medically necessary procedures and drugs to treat precocious puberty and a list of other indications that did not include gender transition.

Both of these provisions were removed from the final version passed by the Senate and signed by President Trump on July 4; specifically, the Senate Parliamentarian struck them from the bill after determining that they violated the “Byrd Rule”—a procedural rule that requires all provisions to be related to the purpose of budget reconciliation.

Restrictions on Medicaid funding for reproductive health remain

The only restriction on reproductive health that remains in the final version of the bill is Section 71113, entitled “Federal Payments to Prohibited Entities.” This provision prohibits all direct Medicaid spending to providers “primarily engaged in family planning services, reproductive health, and related medical care” if they also provide abortions. Importantly, the Medicaid spending prohibition applies to any of the services they provide, not just abortion services.

The prohibition will remain in place for one year, until July 4, 2026. Additionally, it applies only to entities that, as of October 1, 2025, are 501(c)(3) organizations,  “essential community providers” as described in 45 C.F.R. 156.235, and for which the total amount of federal and state expenditures under the Medicaid program in Fiscal Year 2023 exceeded $800,000.

The effect of this provision is sweeping. It not only prohibits clinics whose primary purpose is to provide abortion services from receiving Medicaid funding, but also prohibits clinics engaged in providing a wide range of services—like STI testing, birth control, and cancer screenings—from receiving any Medicaid funding.

This final version is both more inclusive and less imposing than the House version. While the House version included a $1 million threshold to be deemed a prohibited entity, which would have exempted smaller entities from the law, it also would have been in place for ten years, instead of one.

Planned Parenthood has challenged the provision

Shortly after the law was signed, Planned Parenthood Federation of America and its affiliates in Massachusetts and Utah sued the Secretary of Health and Human Services (HHS) in the U.S. District Court for the District of Massachusetts seeking to block enforcement of the provision. Planned Parenthood Federation of America v. Kennedy, No. 1:25-cv-11913 (D. Mass. Jul. 7, 2025). In its complaint, the group claimed that the provision’s limitations were designed to target Planned Parenthood and its affiliates, specifically.

On July 7, Judge Indira Talwani issued a temporary restraining order, directing HHS to “take all steps necessary to ensure that Medicaid funding continues to be disbursed in the customary manner and timeframes” to Planned Parenthood Federation of America and its members, as well as its affiliates in Massachusetts and Utah. The order, which is limited to Planned Parenthood, will remain in effect for 14 days, unless otherwise modified by the Court. Judge Talwani has scheduled oral argument for July 18 on whether the law violates the Equal Protection Clause of the U.S. Constitution. This case will undoubtedly develop quickly over the coming weeks.

What does this mean for reproductive health care?

These events come only a week after the U.S. Supreme Court ruled that there is no private right of action under Federal law to require South Carolina to include Planned Parenthood-affiliated clinics in its Medicaid program. For more information about this decision, review our blog post  on Medina v. Planned Parenthood South Atlantic, No. 23-1275, 606 U.S. ___ (2025).

The outcome of the Massachusetts litigation will be telling. Additionally, since the law will only remain in place for one year and includes an $800,000 threshold, it remains to be seen whether a patchwork of smaller clinics will be able to fill the void for reproductive health care services resulting from the closure of Planned Parenthoods and other similarly situated clinics throughout the country. However, it is clear that these services could become much more difficult to access as the law goes into effect. 

Reed Smith will continue to monitor developments in reproductive health care, including those stemming from the 2025 Reconciliation Law. If you have any questions, please do not hesitate to reach out to the authors of this post or to your health care lawyers at Reed Smith.

Further Parts of this series: Part 2 discusses the impact on the Medicare program.