AG Nessel Blocks Unlawful Medicaid Work Requirements for the Medically Frail

The Michigan Attorney General filed suit in June 2026 challenging an interim final rule issued by CMS that narrowed the definition of "medically frail" under Medicaid work requirements enacted pursuant to the Big Beautiful Bill Act. The rule made it harder for medically vulnerable individuals to qualify for exemptions from those work requirements and, according to the complaint, increased administrative burdens on states and enrollees while providing insufficient guidance for implementation. The U.S. District Court for the District of Massachusetts held that the CMS interim final rule's definition of "medical frailty" is contrary to law. The court vacated the challenged definitional language, issued a permanent injunction against enforcement, and granted plaintiff states a six-month stay of enforcement to accommodate implementation adjustments necessitated by the ruling. The AG's challenge alleged that the interim final rule disregarded substantial evidence that should have been considered, failed to adequately evaluate reasonable alternatives, and did not provide states clear or workable guidance. The rule was issued after months of state-federal collaboration on implementation, without advance notice to states. Medicaid is jointly funded by states and the federal government, with the federal government covering at least 50% of service costs. Congress established exemptions from Medicaid work requirements for individuals with serious illnesses and disabilities; the challenged rule narrowed access to those exemptions.