AG Campbell Celebrates 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 holding that the Trump Administration's definition of "medical frailty," as adopted in a CMS 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 errors or delays during the initial rollout of Medicaid work requirements. The underlying lawsuit was filed in June 2026 by a multistate coalition co-led by the attorneys general of Massachusetts, California, and New Jersey, joined by attorneys general and governors from more than twenty additional states and the District of Columbia. The complaint challenged an interim final rule in which CMS adopted a new, narrower interpretation of the term "medically frail," making it more difficult for individuals with serious illnesses and disabilities to qualify for exemptions from Medicaid work requirements enacted under the Big Beautiful Bill Act. Congress had created exemptions from Medicaid work requirements to protect individuals with serious illnesses and disabilities from losing coverage or experiencing interruptions in care. The plaintiff states alleged that the CMS interim final rule contradicted those statutory exemptions, imposed additional administrative burdens on states and enrollees, and placed eligible individuals at risk of losing Medicaid coverage despite qualifying for an exemption. The AG's office noted that prior Medicaid work requirement programs have documented that administrative complexity causes eligible enrollees to lose coverage, increasing utilization of safety net providers and emergency rooms and raising costs for state Medicaid programs.