October 30, 2026 ATTORNEY GENERAL RAOUL SECURES VICTORY BLOCKING IMPLEMENTATION OF UNLAWFUL MEDICAID WORK REQUIREMENT FOR MEDICALLY FRAIL INDIVIDUALS

The U.S. District Court for the District of Massachusetts issued a decision on October 30, 2026, holding that the Trump administration's definition of "medical frailty" under an interim final rule implementing Medicaid work requirements pursuant to the One Big Beautiful Bill Act is contrary to law. The court vacated the unlawful definitional language, issued a permanent injunction, and granted the plaintiff states a six-month stay of enforcement to accommodate implementation adjustments. Illinois Attorney General Kwame Raoul filed the underlying lawsuit in June 2026, joined by the attorneys general of 22 additional states and the District of Columbia, as well as the governors of Kentucky and Pennsylvania. The complaint challenged an interim final rule issued by CMS that narrowed the interpretation of key terms, including "medically frail," making it more difficult for medically vulnerable individuals to establish eligibility for the statutory exemption from Medicaid work requirements. Congress included exemptions from Medicaid work requirements to protect individuals with serious illnesses and disabilities from coverage loss or interruptions in care. The plaintiff states alleged that the CMS interim final rule disregarded substantial evidence, failed to adequately evaluate reasonable alternatives, and did not provide states with clear or workable implementation guidance. The states further alleged the rule was issued without adequate notice after months of prior collaborative implementation work. The court's ruling vacates the challenged definitional language and permanently enjoins its enforcement. The six-month stay of enforcement is designed to allow states and CMS to correct any errors or delays arising from the necessary changes to implementation of the work requirement exemption framework.