Medicaid work requirements put into place by the President Donald Trump-backed One Big Beautiful Bill Act are being challenged in federal court by a coalition of states, seeking to block a Final Rule from the Centers for Medicare & Medicaid Services that outlined how they would be implemented.
The lawsuit, led by California and Massachusetts, is joined by Arizona, Colorado, Connecticut, Delaware, District of Columbia, Hawaii, Illinois, Kentucky, Maine, Maryland, Michigan, Minnesota, Nevada, New Mexico, New Jersey, New York, North Carolina, Oregon, Pennsylvania, Rhode Island, Vermont, Virginia, Washington and Wisconsin, representing both “blue” and “red” states, showing that the work requirements have some bipartisan opposition in state governments.
In a press release, Massachusetts Attorney General Andrea Joy Campbell said the interim final rule from CMS—published on June 3—is failing to protect the list of exclusions to the work requirements that Congress put in place to “ensure that people with serious illnesses and disabilities do not lose coverage or face interruptions in care.”
According to Campbell, speaking on behalf of the plaintiffs, CMS’s rule is an “abrupt change” that, if allowed to stand, would “make it significantly harder for vulnerable individuals to qualify for exclusions from the Medicaid work requirements and harder to maintain Medicaid coverage.”
The sticking point is how the term “medically frail” is defined—a key category that would allow an individual access to Medicaid regardless of their status as an employee or a student. Being medically frail generally refers to having a serious or chronic physical, mental, or medical condition that makes it hard to sustain steady work or perform normal daily activities without significant help. [1]
- Are blind or have a disability as defined by the Social Security Administration.
- Have a substance use disorder (SUD).
- Suffer from a disabling mental health condition.
- Have a physical, intellectual, or developmental disability that significantly impairs their ability to perform Activities of Daily Living (ADLs).
- Live with serious or complex medical conditions, such as cancer or HIV. [1, 2]
CMS’s requirement would force people who are in need of healthcare services to find specialty jobs to accommodate them, where none may exist, the plaintiffs argue. The states contend that the agency appears to be trying to ensure this exemption is effectively nullified.
“The Trump Administration’s attempt to impose new, burdensome requirements on Medicaid recipients threatens access to healthcare for our most vulnerable residents and families,” Campbell said in a statement. “Congress made clear that people with serious medical conditions should not lose coverage.”
“We are asking the court to block these unlawful provisions to protect Medicaid recipients and prevent needless strain on Massachusetts’ healthcare system.”
Burden of proof
As for the specifics of the legal challenge, the states are asking a court to force CMS to change the rule, contending that it violated the Administrative Procedure Act and bypassed Congress’s intent to add real safeguards for Americans to access safety net healthcare services.
Further, the coalition says states will be left holding the bag, dealing with the fallout from a population with significant medical needs that can’t access Medicaid because of the overly strict federal mandates, particularly a reporting burden that effectively forces states to prove a citizen is “medically frail.”
The lawsuit has yet to be heard in front of a federal judge.
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