Attorney General Bonta Secures Major Victory Blocking Implementation of Unlawful Medicaid Work Requirements for Medically Frail Individuals

On October 29, 2026, the U.S. District Court for the District of Massachusetts issued a decision in a multistate lawsuit led by California Attorney General Rob Bonta, finding the Trump Administration's implementation of Medicaid work requirements under the Big Beautiful Bill Act unlawful. The court held that CMS's interim final rule definition of "medical frailty" is contrary to law, vacated the challenged language, and issued a permanent injunction against its enforcement. The plaintiff states filed suit in June 2026 challenging an interim final rule in which CMS adopted a narrowed interpretation of the term "medically frail," making it more difficult for medically vulnerable individuals to qualify for exemptions from Medicaid work requirements. The complaint alleged the rule disregarded substantial evidence, failed to adequately evaluate reasonable alternatives, and did not provide states with clear or workable guidance. The court also granted the plaintiff states a six-month stay of enforcement to accommodate errors or delays resulting from necessary changes to program implementation. Medicaid is jointly funded by states and the federal government, with the federal government providing at least 50% of the cost of services. The states alleged that past Medicaid work requirement programs demonstrate that increased administrative burdens cause eligible individuals to lose coverage, placing greater strain on state Medicaid programs, safety net providers, and emergency departments, while raising costs as more medically frail residents become uninsured.