A federal judge ruled that the Trump administration exceeded its authority by narrowing the definition of “medically frail” under new Medicaid work requirements, blocking a restriction that states argued could cause vulnerable Americans to lose health coverage.
By yourNEWS Media Newsroom
BOSTON — A federal judge on Thursday struck down part of the Trump administration’s Medicaid work requirement regulations, ruling that federal health officials unlawfully narrowed exemptions for people with serious medical conditions ahead of the program’s scheduled implementation on January 1, 2027.
U.S. District Judge Richard Stearns of Massachusetts sided with 25 states and the District of Columbia in a lawsuit challenging the Centers for Medicare and Medicaid Services’ interpretation of who qualifies as medically frail and therefore exempt from the new work requirements.
The October 29 ruling, reported by Politico, blocks the administration from enforcing a definition that would require people with qualifying health conditions to demonstrate that those conditions significantly interfere with their ability to satisfy work or community engagement requirements.
Stearns determined that the agency had imposed a restriction beyond what Congress authorized when lawmakers established the exemptions.
The decision does not invalidate the Medicaid work requirements themselves, which were enacted as part of President Donald Trump’s sweeping tax and spending legislation signed into law in July 2025.
Instead, the ruling addresses how federal regulators interpreted one of the statutory exemptions intended to protect people with serious medical conditions.
Under the legislation, certain adults ages 19 through 64 must complete at least 80 hours of qualifying activities each month to maintain Medicaid eligibility.
Those activities generally include employment, community service, job training or educational participation. Enrollment in an educational program at least half time can also satisfy the requirement.
The law establishes exceptions for certain groups, including individuals who are medically frail or have special medical needs.
CMS issued an interim final rule in June 2026 establishing procedures for states to implement the requirements.
The regulation defined medically frail individuals in part by whether a physical, mental or behavioral health condition significantly impaired their ability to comply with the monthly community engagement requirements.
The states challenging the regulation argued that this additional limitation improperly narrowed the exemption Congress had established.
Under their interpretation, individuals with qualifying medical conditions should not also be required to prove that their conditions prevent or significantly interfere with their ability to work.
The distinction could affect people living with chronic illnesses, serious mental health conditions, substance use disorders, disabilities or other complex medical needs.
Stearns agreed that the administration’s interpretation imposed an unauthorized limitation.
“Because enforcement of an unlawful definition of ‘medically frail’ may lead to the disenrollment of otherwise eligible vulnerable individuals relying on Medicaid coverage for continuity of care, the States (and public) face potential for great hardship in the absence of an injunction,” the judge wrote, according to Reuters.
The decision prevents CMS from enforcing the challenged definition while leaving other portions of the agency’s implementation framework intact.
Stearns, who was appointed to the federal bench by President Bill Clinton, rejected other arguments raised by the states against the regulations.
The lawsuit was led by attorneys general from California, Massachusetts and New Jersey and included 22 additional states and the District of Columbia.
The plaintiffs maintained that the regulations would force states to impose unnecessary verification requirements on people already eligible for exemptions under federal law.
They also warned that complicated documentation procedures could result in eligible residents losing their health insurance because of administrative barriers rather than a failure to satisfy substantive eligibility requirements.
The ruling follows an earlier decision in the same litigation.
In July, Stearns denied the states’ request for a preliminary injunction, concluding at the time that they had not sufficiently demonstrated the immediate harm necessary to justify blocking the regulations before the court completed its review.
That earlier decision did not resolve whether CMS had exceeded its statutory authority.
The judge subsequently established an expedited schedule to consider the merits of the case before the January implementation deadline.
Thursday’s ruling represents a different legal determination following that more extensive review.
The dispute arose from the Medicaid provisions of the One Big Beautiful Bill Act, which established nationwide community engagement requirements for many adults receiving benefits through Medicaid expansion.
The program provides health insurance coverage to qualifying low-income individuals and is jointly financed by federal and state governments.
Under the new federal requirements, states must establish systems for verifying whether covered individuals meet the monthly activity standards or qualify for an exemption.
Those procedures can involve checking employment records, education enrollment, participation in community service programs or documentation of qualifying medical conditions.
Supporters of work requirements argue that they encourage employment, increase personal responsibility and preserve taxpayer-funded assistance for individuals who meet eligibility conditions.
Critics argue that the requirements create administrative complications and could cause eligible people to lose coverage even when they are working or have qualifying medical conditions.
The disagreement over medical frailty has been a central issue because some beneficiaries may have serious health conditions without being entirely unable to work.
Medical organizations have argued that requiring patients to demonstrate a significant impairment in their ability to satisfy work requirements could create additional barriers to medical care.
The American Medical Association and several national physician organizations supported challenges to the administration’s regulations.
In an October 27 statement, the AMA announced that it had joined other medical groups in filing a court brief opposing the restrictions.
The organizations argued that the narrower interpretation conflicted with the exemption Congress enacted and could disrupt care for people with serious or complex conditions.
The groups also raised concerns about the workload placed on physicians who might be required to complete additional forms or document how medical conditions affect patients’ ability to comply with the requirements.
In a separate October 23 analysis, the association acknowledged that CMS had provided additional guidance intended to help states identify medically frail beneficiaries using existing medical records.
The agency’s guidance described a process allowing states to review available healthcare information and determine whether some individuals qualify without requiring additional documentation.
However, the AMA maintained that the underlying definition remained overly restrictive.
The organization also questioned limitations on self-attestation, a process that allows individuals to report qualifying conditions without immediately submitting medical documentation.
Under the administration’s original framework, states could temporarily accept self-attestation during the initial implementation period, with stricter documentation requirements beginning in 2028.
Medical groups argued that those restrictions could create problems for patients who experience difficulty obtaining timely medical records or arranging physician appointments.
The broader Medicaid work requirement law is expected to affect millions of Americans receiving coverage through Medicaid expansion.
A Congressional Budget Office assessment of the 2025 legislation estimated that the Medicaid provisions would reduce federal spending substantially over the following decade while increasing the number of uninsured Americans.
The precise effects will depend on how states implement the requirements, how many individuals qualify for exemptions and whether beneficiaries can complete the necessary verification procedures.
Thursday’s ruling addresses one component of those implementation questions.
By rejecting CMS’ additional impairment standard, the court limits the federal government’s ability to require medically frail individuals to demonstrate that their conditions substantially interfere with participation in work-related activities.
The decision does not automatically exempt every Medicaid beneficiary with a medical diagnosis from the new requirements.
Individuals must still meet the applicable statutory criteria, and states remain responsible for determining eligibility under federal law.
The administration could seek appellate review of the ruling or issue revised regulations consistent with the court’s interpretation.
CMS did not immediately respond to a request for comment following the decision, according to Reuters.
With the nationwide requirements scheduled to take effect January 1, states face a limited period to adjust eligibility systems and administrative procedures.
The ruling establishes that CMS cannot enforce the challenged medical frailty definition while preserving the broader statutory requirement for qualifying Medicaid recipients to participate in work, education or community engagement.
The decision therefore leaves the central work requirement policy in place but changes how federal officials may determine which medically vulnerable Americans are exempt.
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