Attorney General Brown Announces Court Victory Blocking Implementation of Unlawful Medicaid Work Requirements for Medically Frail Individuals Published: 10/30/2026

The U.S. District Court for the District of Massachusetts issued a ruling holding that the Trump administration's definition of "medical frailty," as adopted in a CMS interim final rule implementing Medicaid work requirements under the "One Big Beautiful Bill Act," is unlawful. The court struck down the definition, issued a permanent injunction against its enforcement, and granted a six-month stay of enforcement to accommodate implementation changes required of the states. Maryland Attorney General Anthony G. Brown joined a multistate coalition in filing the lawsuit in June 2026, challenging provisions of the interim final rule that adopted a narrowed interpretation of key terms, including "medically frail," making it harder for medically vulnerable individuals to obtain exemptions from Medicaid work requirements. The coalition argued that the rule disregarded substantial evidence, failed to evaluate reasonable alternatives, and did not provide states with clear or workable guidance. Maryland had estimated that approximately 150,000 Marylanders, representing 45% of adults covered through the state's ACA Medicaid expansion, were at risk of losing coverage under the rule. The rule was also estimated to impose $2 million in additional administrative burdens on the state. The coalition cited prior Medicaid work requirement programs as evidence that administrative complexity causes eligible individuals to lose coverage. CMS issued the challenged rule as an interim final rule earlier in 2026. Congress had created statutory exemptions from Medicaid work requirements to protect individuals with serious illnesses and disabilities, and the coalition's central challenge was that the rule's redefinition of "medical frailty" conflicted with those exemptions and the underlying statutory framework.