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We were unable to process your request. Please try again later. If you continue to have this issue please contact customerservice@slackinc.com. Back to Healio Key takeaways: People who fall under a medical frailty category will not have to demonstrate their condition impairs their ability to meet work requirements. The ruling does not overturn the broader Medicaid work requirements. A federal judge struck down a CMS rule requiring Medicaid beneficiaries with qualifying medical conditions to prove they cannot meet new work requirements. The order does not overturn the broader Medicaid work requirements enacted under H.R.1, or the One Big Beautiful Bill.
People who fall under a medical frailty category will not have to demonstrate their condition impairs their ability to meet work requirements. Image: Adobe Stock
Starting Jan. 1, certain Medicaid beneficiaries aged 19 to 64 years will be required to engage in qualifying activities \u2014 employment, community service or some work programs \u2014 for 80 hours per month, or make at least $580 monthly (the minimum wage multiplied by 80 hours), \u201cor be enrolled in educational program for at least half time,\u201d according to CMS. Individuals who fall within one of the following medical frailty categories will be exempt from the work requirements: being blind; having a substance use disorder; having a disabling mental disorder; having a physical, developmental or intellectual disability that interferes with activities of daily living; or having a serious or complex medical condition. In June, CMS added a stipulation that would have required beneficiaries with qualifying medical conditions to demonstrate that their condition significantly impairs their ability to meet the work requirements. In Commonwealth of Massachusetts v. Oz, 25 states and Washington, D.C., argued that this additional rule \u201cunlawfully narrowed the medical frailty exemption Congress established,\u201d according to an AMA press release. The AMA, along with 10 other medical societies, had filed an amicus brief in the case on Sept. 10, which argued the change \u201ccould cause eligible patients to lose Medicaid coverage,\u201d a press release said. U.S. District Judge Richard G. Stearns, JD, ruled that CMS could not impose an impairment test on beneficiaries who meet the medical frailty categories CMS \u2018lacked authority\u2019 for definition Stearns wrote in the order that CMS \u201clacked authority to exclude any subset of individuals\u201d within the five categories. \u201cBecause enforcement of an unlawful definition of \u2018medically frail\u2019 may lead to the disenrollment of otherwise eligible vulnerable individuals relying on Medicaid coverage for continuity of care, the states (and public) face potential for great hardship in the absence of an injunction,\u201d he wrote. The order upholds CMS\u2019 work requirement and a requirement that states reject proof of patients’ medical frailty if the diagnosis is over a year old. It also allows states to accept just one self-attestation every continuous period of enrollment. Stearns explained the states\u2019 arguments against these were \u201cunconvincing and falling well short of the arbitrary or capricious standard under the\u201d Administrative Procedures Act. \u201cThe government provided a non-frivolous rationale for adopting each provision and explained why it did not find the states\u2019 concerns of disenrollment compelling,\u201d he wrote. \u2018A victory for patients\u2019 The ruling \u201cis a victory for patients as it strikes back against unnecessary barriers to care,\u201d AMA President Willie Underwood III, MD, MSc, MPH, said a statement. \u201cThe court rightly rejected a federal restriction that would have made it harder for people with serious or complex health conditions to qualify for an exemption from Medicaid work requirements,\u201d Underwood III said. \u201cPatients should not have to clear unnecessary bureaucratic hurdles to keep their health coverage, especially hurdles that go beyond what Congress intended.\u201d The ruling would have adversely impacted eligibility, Underwood III argued, because a patient\u2019s condition may not always fit the agency\u2019s definition at every point in time. \u201cSymptoms can fluctuate. Treatment can be debilitating. A person may be able to work at one point but be unable to manage the demands of work at another,\u201d he said. Underwood III added the ruling would have further created additional administrative burden for clinicians \u2014 requiring them to determine if a patient\u2019s condition would impair their ability to comply with work requirements, which \u201cis time taken away from patient care\u201d \u2014 while affecting physician-patient relationships by dissuading patients from discussing pain, fatigue, mental health issues and substance use \u201cif they fear those conversations could affect their coverage.\u201d \u201cCMS should stop putting barriers between medically frail patients and the care they need,\u201d he said. \u201cPhysicians should spend their time treating patients, not proving that those patients deserve to keep their Medicaid coverage.\u201d Sources\/Disclosures Source:
Press Release
References: CMS launches nationwide framework to implement Medicaid work requirements. https:\/\/www.cms.gov\/newsroom\/press-releases\/cms-launches-nationwide-framework-implement-medicaid-work-requirements. Published June 1, 2026. Accessed Oct. 30, 2026. Commonwealth of Massachusetts, et al. v. Oz. https:\/\/fingfx.thomsonreuters.com\/gfx\/legaldocs\/gdvzggnjmpw\/10292026work.pdf. Published Oct. 29, 2026. Accessed Oct. 30, 2026. Medicaid community engagement requirement for certain individuals interim final rule with comment period (CMS-2454-IFC). https:\/\/www.cms.gov\/newsroom\/fact-sheets\/medicaid-community-engagement-requirement-certain-individuals-interim-final-rule-comment-period-cms. Published June 1, 2026. Accessed Oct 30, 2026. Medicaid rules must not put vulnerable patients at risk. https:\/\/www.ama-assn.org\/about\/leadership\/medicaid-rules-must-not-put-vulnerable-patients-risk. Published Oct. 28, 2026. Accessed Oct. 30, 2026. US judge blocks Trump limits to Medicaid work requirement exceptions. https:\/\/www.reuters.com\/legal\/government\/us-judge-blocks-trump-limits-medicaid-work-requirement-exceptions-2026-10-29\/. Published Oct. 29, 2026. Accessed Oct. 30, 2026.
Disclosures:
Healio could not determine relevant financial disclosures at the time of publication.
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