Win for Washington as judge blocks unlawful federal implementation of Medicaid work requirements

On October 29, 2026, the U.S. District Court for the District of Massachusetts held that the Trump Administration's implementation of Medicaid work requirements under the Big Beautiful Bill Act (H.R. 1) was contrary to law. The court vacated the challenged regulatory language, issued a permanent injunction against enforcement, and granted plaintiff states a six-month stay of enforcement to accommodate implementation adjustments. The challenged rule, titled "Community Engagement Requirement for Certain Individuals," was issued by CMS as an interim final rule in June 2026. The rule adopted a new, narrower interpretation of the term "medically frail," making it more difficult for medically vulnerable Medicaid beneficiaries to qualify for exemptions from the statutory work requirements that Congress built into the program. Washington State, together with a multistate coalition, filed suit in June 2026 challenging the rule. The court held that the administration's definition of "medical frailty" is contrary to law, the central basis for vacatur and the injunction. Washington's Apple Health program covers approximately 1.9 million individuals, including populations experiencing homelessness and those with serious or complex medical conditions. The state AG's office argued that prior Medicaid work requirement programs demonstrated that administrative requirements cause eligible individuals to lose coverage and increase costs on state programs, safety-net providers, and emergency departments.