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Policy & oversight

Federal Judge Blocks Part of Medicaid Work Rule That Narrowed Who Counts as Medically Frail

A U.S. district court found that CMS wrote an unlawfully restrictive definition of "medically frail" for the new Medicaid work requirements, blocking its enforcement in 25 states and the District of Columbia. The ruling directly touches Medicare beneficiaries who also rely on Medicaid.

By the Goodsurance editorial teamOctober 31, 2026

U.S. District Judge Richard D. Stearns of the District of Massachusetts has blocked the Trump administration from enforcing the Centers for Medicare and Medicaid Services definition of "medically frail" in 25 states and the District of Columbia, finding it overly restrictive and potentially harmful to vulnerable enrollees.

The ruling arose from Commonwealth of Massachusetts v. Oz, a case brought by 25 state attorneys general and the District of Columbia challenging the Medicaid work requirements regulation issued under the 2025 federal law commonly called the One Big Beautiful Bill. That law imposed, for the first time at the federal level, community engagement requirements for most working-age Medicaid enrollees. The law exempts people classified as medically frail. CMS's implementing rule, however, narrowed that exemption in ways the plaintiff states said went beyond what the statute allows.

A federal judge blocked part of the Medicaid work rule's sick-person exemption in 25 states. Many Medicare beneficiaries who also have Medicaid have the most at stake.

Judge Stearns agreed, ruling that enforcement of the definition would cause "irreparable harm" and could lead to the "disenrollment of otherwise eligible vulnerable individuals relying on Medicaid coverage for continuity of care." The injunction applies only to the 26 plaintiff jurisdictions. Medicaid enrollees in states that did not join the lawsuit remain subject to the full rule, and the administration is expected to appeal.

The ruling carries weight for Medicare because a significant share of Medicare beneficiaries are also enrolled in Medicaid. These dual-eligible individuals rely on Medicaid to cover Medicare cost-sharing, certain premiums, and services that Medicare does not pay for on its own. A Medicaid disenrollment triggered by an unlawfully narrow frailty standard would therefore also strip those individuals of their Medicare financial protections. The Medicare Rights Center, which tracks Medicare consumer issues, flagged the ruling as a development of direct concern to the Medicare population.

In plain words

A federal judge in Boston said the government made an unfair rule about who counts as too sick to work. A 2025 law says most Medicaid members have to do 80 hours of work or community activities each month or lose coverage. Very sick people were supposed to be automatically excused. But the government added an extra test that the judge said was not allowed by law. The judge stopped that extra test in 25 states and Washington, D.C. This matters for Medicare because many people have both Medicare and Medicaid at the same time. If they lost Medicaid under the unfair test, they would also lose extra help paying their Medicare bills. The ruling does not help people in states that were not part of the lawsuit. The government is expected to fight the ruling in a higher court.

Source: Medicare Rights Center
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