Attorney General Tong Announces Major Victory Blocking Implementation of Unlawful Medicaid Work Requirements

The U.S. District Court for the District of Massachusetts ruled in favor of Connecticut and a coalition of plaintiff states in a multistate challenge to a CMS interim final rule implementing Medicaid work requirements under the Big Beautiful Bill Act. The court held that the Trump Administration's definition of "medical frailty" is contrary to law, vacated the challenged regulatory language, and issued a permanent injunction against its enforcement. The court also granted the plaintiff states a six-month stay of enforcement to accommodate implementation changes necessitated by the ruling. Connecticut Attorney General William Tong joined the multistate lawsuit in June 2026, targeting provisions of the interim final rule that adopted a narrowed interpretation of key statutory terms, including "medically frail." The complaint alleged that the revised definition made it harder for medically vulnerable Medicaid enrollees to qualify for exemptions from the work requirement provisions established under the Big Beautiful Bill Act. CMS issued the interim final rule after months of working with states on implementation, introducing changes that the plaintiff states alleged increased administrative burdens, created additional procedural barriers, and placed eligible enrollees at risk of losing coverage. The plaintiff states argued the rule's redefinition of "medically frail" was inconsistent with the statutory exemptions Congress established to protect individuals with serious illnesses and disabilities from coverage loss or interruption due to work requirements. The court's order vacates the challenged regulatory language and the permanent injunction blocks further enforcement. The six-month stay provides the federal government and states a remediation period to address implementation errors or delays arising from the changes required by the decision.