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A coalition of 25 states and the District of Columbia is suing the Trump administration over a new rule implementing Medicaid work requirement exemptions for medically frail people.
According to the lawsuit, which was filed Monday in federal district court in Massachusetts, the Centers for Medicare and Medicaid Services (CMS) violated congressional protections when it issued an interim final rule concerning who is eligible for exemptions from new Medicaid work requirements.
The lawsuit alleges the administration adopted a rule that “dramatically narrowed the Congressionally established exclusions from the work requirement for some of the most vulnerable Medicaid members.”
The states argue the new rule will lead people who are either already working or eligible for an exclusion to lose or be denied coverage.
The rule “creates new requirements that constrain who is exempt due to their medically frail status and force medically frail individuals in need of healthcare to jump through unnecessary administrative hoops to get and retain life-saving healthcare coverage,” the lawsuit argues.
The rule issued earlier this month is meant to guide 42 states and the District of Columbia in carrying out the work rules implemented by the One Big Beautiful Bill Act. GOP lawmakers and administration officials have described the policy as a way to combat waste, fraud and abuse in the Medicaid program.
The work requirements are set to take effect in January. Beneficiaries who are part of the Medicaid expansion population must work or volunteer at least 80 hours per month, attend school at least part time or participate in job training.
The law included a series of exceptions for certain vulnerable populations, including a carve-out for people who are “medically frail.” But there was no clear definition of what that meant.
The new rules implicitly link the definition of medical frailty to a person’s ability to work. To qualify for an exemption, a person must demonstrate that their condition prevented them from meeting the work requirement.
States had been discussing implementation plans with the CMS for months ahead of the rule and were blindsided by the much stricter definition. The new standard was not included in the law.
As a result, states argued people who should be protected under the law may lose coverage because they cannot get through the administrative barriers to prove they qualify.
“These changes fly in the face of substantial evidence that was or should have been considered by the agency in its decisionmaking, without adequately considering reasonable alternatives or significant downsides, and without making clear what is being asked of Plaintiff States,” the lawsuit argued.
The states claimed Congress was deliberately broad when they wrote the law.
“But H.R. 1’s broad statutory exclusions exist for good reason. People with disabilities, patients in the middle of cancer treatment, or those struggling with another serious or complex health condition, shouldn’t be at risk of losing the care that helps maintain their health,” the lawsuit states.
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