Alliance Alert: We are encouraged by today’s federal court ruling striking down the Trump administration’s restrictive definition of “medically frail” under the upcoming Medicaid work requirements. While this decision does not eliminate the new work requirements, it could allow more people with significant health conditions, including mental health and substance use challenges, to qualify for exemptions and maintain their Medicaid coverage.
Importantly, the ruling also requires states to wait at least six months after the work requirements take effect before disenrolling individuals who claim a medical exemption. This additional time will allow states to update their verification systems and could help prevent eligible people from losing access to essential health and recovery services.
Although this is a positive development, significant concerns remain about the administrative burdens and potential coverage losses associated with the new requirements. We also anticipate that the federal government will appeal this decision, meaning the protections established by the ruling could face further legal challenges.
The Alliance continues to believe that people should not lose access to essential health coverage because of complicated reporting requirements or barriers to documenting their eligibility. This is particularly important for people with mental health and substance use challenges who rely on consistent access to community-based services and supports to maintain their recovery.
As New York prepares for the implementation of Medicaid work requirements in January 2027, the Alliance will continue closely monitoring this ruling, its potential appeal, and the implementation of work requirements and other federal Medicaid changes. We will keep our members and partners informed about developments, available exemptions, and steps that can help New Yorkers maintain their health coverage and access to critical services.
Judge Strikes Down Trump Admin’s Definition of ‘Medically Frail’ in Medicaid Work Rules
Alice Miranda Ollstein, Robert King | Politico | October 29, 2026
A federal judge in Boston sided on Thursday with a coalition of 25 Democratic-led states and the District of Columbia in a lawsuit challenging the Trump administration’s requirement that states force chronically ill people on Medicaid to prove they are unable to work.
During oral arguments last week, the states said that unless the court blocked that piece of the rule before January and allowed them to exempt people with certain diagnosed illnesses, they would be “forced… to bear the costs and burdens of operationalizing this unlawful limitation.”
Judge Richard Stearns, an appointee of President Bill Clinton, said the guidance the Centers for Medicare and Medicaid Services released in June went too far beyond the law Congress passed in 2025, and is “thus contrary to law.”
“There is an inherent public interest in ensuring that the government follows the law,” he said, adding that “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 court also ordered states to hold off for at least six months after the work rules take effect before they cancel the health insurance of anyone claiming a medical exemption to give them time to update their verification systems to comply with the ruling.
The ruling blocks only the “medical frailty” portion of the law and leaves the rest of the Medicaid work requirements, which will be enforced nationally beginning in January, in place.
CMS did not immediately return a request for comment.
Stearns reject challenges from the states to other aspects of the law. The judge, for instance, sided with the government on a requirement that states reject proof of patients’ medical frailty — like a hospital admission or diagnosis — that is more than 12 months old.
States argued the provision will lead to greater disenrollments because sometimes a frail individual will go longer than 12 months between major health services.
The judge ruled that CMS provided a rationale for that “lookback” provision and therefore it was not arbitrary as the states contended.
“That the states (or even the court) may disagree with the wisdom of the agency’s policies and conclusions, or may have made different choices, is irrelevant,” he wrote.
Stearns also sided with the Trump administration on its policy letting states decide whether or not to accept a patient’s pledge that they are too sick to work in lieu of hard proof for the first year the work requirement is in effect.
Starting in 2028, Medicaid expansion enrollees nationwide can self-attest once but then during their next renewal they must prove that their condition prevents them from working.
Eight states have rejected the one year grace period and will require that paperwork in 2027, arguing that allowing patients to ‘self-attest’ could lead to fraudulent enrollments.
The states’ case argued that the Trump administration should have required all states to accept self-attestation of medical frailty.
Another lawsuit challenging the policy, filed by medical groups and the city of Columbus, Ohio, remains pending in a Maryland federal court.