25 States and D.C. Sue Over Federal Rule Defining Medical Frailty for Medicaid Work-Requirement Exemptions

A coalition of 25 states and the District of Columbia filed a lawsuit Monday in federal district court in Massachusetts against the Trump administration over a new Centers for Medicare and Medicaid Services rule on Medicaid work requirement exemptions.

The suit challenges an interim final rule issued earlier this month that defines medical frailty for purposes of exemptions under the One Big Beautiful Bill Act. The rule requires individuals to demonstrate that their condition prevented them from meeting the work requirement to qualify for an exemption.

Under the law, Medicaid expansion beneficiaries ages 19 to 64 must work or volunteer at least 80 hours per month, attend school at least part time, or participate in job training starting January 1. The statute includes exceptions for people who are medically frail, including those with substance use disorders, disabilities or serious medical conditions.

The CMS rule states that a person's condition must impair their ability to work, volunteer or attend school at the required rates.

In 2027 and once in 2028, patients can attest they meet the definition; when renewing coverage in 2028 they must provide proof. The complaint alleges the rule oversteps the text of the law passed last summer and creates new administrative barriers not included in the statute. , as defendant.

The lawsuit states that the changes constrain who qualifies for an exemption due to medically frail status and force individuals to navigate additional requirements to obtain or retain coverage.