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

On October 29, 2026, a federal district court issued a decision in a multistate lawsuit, filed in June 2026, challenging an interim final rule promulgated by CMS governing Medicaid work requirements under the Big Beautiful Bill Act. The court held that the Administration's definition of "medical frailty," as adopted in the interim final rule, is contrary to law. The court vacated the challenged language, issued a permanent injunction against its enforcement, and granted the plaintiff states a six-month stay of enforcement to accommodate implementation changes. The challenged interim final rule adopted a narrower interpretation of the term "medically frail," a statutory category Congress created to exempt individuals with serious illnesses and disabilities from Medicaid work requirements. The plaintiff states alleged that the rule made it harder for medically vulnerable individuals to qualify for the exemption, increased administrative burdens on states, and failed to provide clear or workable guidance for implementation. The states further alleged that CMS disregarded substantial evidence that should have been considered and failed to adequately evaluate reasonable alternatives before issuing the rule. Arizona Attorney General Mayes joined the multistate coalition as a named plaintiff. The states argued that the rule's redefinition of "medically frail" placed eligible enrollees at risk of losing Medicaid coverage, including individuals already meeting work requirements or qualifying for a statutory exemption. The complaint cited prior Medicaid work requirement programs as evidence that administrative red tape causes eligible individuals to lose coverage and increases costs to state Medicaid programs, safety net providers, and emergency rooms.