McLAUGHLIN, Circuit Judge:
Effective January 5, 1987, the New York State Department of Social Services (the "Department") promulgated new regulations permitting it to terminate, without cause, the participation of a provider of benefits under the State Medicaid program. See 18 N.Y.C.R.R. § 504.7(a). Until 1987, the Department terminated providers only for cause. See 18 N.Y.C.R.R. Part 515. Because termination for cause involves allegations of fraud...
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