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

On October 29, 2026, the U.S. District Court for the District of Massachusetts issued a decision holding that the Trump Administration's implementation of the "medically frail" exemption under the One Big Beautiful Bill Act (OBBBA) was contrary to law. The court vacated the challenged regulatory language, issued a permanent injunction, and granted plaintiff states a six-month stay of enforcement to accommodate implementation changes. The underlying dispute arose from a CMS interim final rule promulgated in 2026 that narrowed the statutory "medically frail" exemption from the OBBBA's Medicaid work requirements. The rule added a requirement that states assess whether a beneficiary's condition significantly impairs their ability to work, a criterion the court found CMS lacked statutory authority to impose. The OBBBA's exemptions were designed to protect individuals with serious or complex conditions, mental disorders, substance use disorders, and other medically vulnerable individuals from losing coverage or facing interruptions in care. The multistate coalition, co-led by the attorneys general of New Jersey, California, and Massachusetts, filed suit in June 2026. Twenty-two additional state attorneys general and the governors of Kentucky and Pennsylvania joined the action. The states argued the interim final rule conflicted with the statutory requirements Congress established for the medical frailty exemption. The court's ruling prevents CMS from enforcing the narrowed definition of "medically frail" pending implementation of compliant procedures. New Jersey's Office of Attorney General noted that prior Medicaid work requirement programs have resulted in eligible individuals losing coverage due to administrative burdens, increasing strain on state Medicaid programs, safety net providers, and emergency departments.