Attorney General Clark Celebrates Major Victory Blocking Implementation of Unlawful Medicaid Work Requirements for Medically Frail Individuals

A federal court ruled against the Trump Administration's implementation of Medicaid work requirements under the Big Beautiful Bill Act, specifically vacating CMS's interim final rule redefining the term "medically frail." Vermont Attorney General Charity Clark joined a multistate coalition in June 2026 challenging provisions of that interim final rule, which adopted a narrower interpretation of "medically frail" that made it harder for medically vulnerable individuals to qualify for exemptions from work requirements. The court held that the Administration's definition of "medical frailty" is contrary to law. The ruling vacated the contested language, issued a permanent injunction against its enforcement, and granted plaintiff states a six-month stay of enforcement to accommodate changes to implementation resulting from the decision. The challenged interim final rule was issued by CMS after months of coordination with states on implementation. According to the Vermont AG's office, the rule increased administrative burdens on beneficiaries seeking exemptions, failed to give states clear or workable guidance, disregarded substantial evidence, and did not adequately evaluate reasonable alternatives. The rule applied to individuals who are medically vulnerable, including those already working or otherwise qualifying for a statutory exemption. Congress established exemptions from Medicaid work requirements to protect individuals with serious illnesses and disabilities from losing coverage or experiencing interruptions in care. The Vermont AG's press release notes that prior Medicaid work requirement programs with added administrative requirements resulted in eligible individuals losing coverage, increasing strain on state Medicaid programs, safety net providers, and emergency rooms.