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California DHCS (Medi-Cal) · November 3, 2026 · Primary source

Interim Final Rule/Medical Frailty Decision Statement

Score 85PRIMARYregulatoryState MedicaidCA

Summary

On October 29, 2026, a federal court ruled that CMS exceeded its statutory authority by imposing additional requirements on individuals seeking to qualify for the medical frailty exemption from the Medicaid work and community engagement requirements established by H.R. 1. The court issued an injunction removing the contested CMS interim final rule provisions that required medically frail individuals or those with special medical needs to demonstrate their condition significantly impairs their ability to meet the work requirement. California's Department of Health Care Services issued a statement describing the ruling and affirming the state's continued implementation of H.R. 1 consistent with federal law.

What this may mean

The federal court injunction invalidates CMS's narrowed medical frailty exemption criteria, restoring a broader class of medically vulnerable Medicaid beneficiaries to exemption eligibility without the additional impairment-showing requirement CMS had imposed. States administering Medicaid work requirements must now apply the medical frailty exemption as Congress defined it, without the additional CMS overlay. California DHCS is reviewing the order and injunction as it continues implementing H.R. 1 Medicaid changes effective January 1, 2027.

Informational only. Not legal, medical, financial, or other professional advice. Always consult a qualified professional familiar with your specific facts before relying on any item.

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