The legal battle over Medicaid work requirements is intensifying. A new lawsuit filed on behalf of five Medicaid enrollees and major provider groups — including the American College of Physicians and the American Academy of Pediatrics — is challenging CMS's interim final rule implementing work requirements mandated by the One Big Beautiful Bill Act. The plaintiffs argue that CMS has quietly narrowed the "medical frailty" exemption beyond what Congress originally intended, requiring enrollees to prove not just that they have a serious condition, but that it specifically prevents them from fulfilling the 80-hour monthly work, education, or volunteer requirement.

The lawsuit also takes aim at the rule's administrative mechanics. It argues that a 12-month lookback window for claims data is too short — a 24-month window would capture more eligible enrollees — and that placing the burden of verifying medical frailty on physicians oversteps the patient-provider relationship. "As physicians, we are trained to diagnose and treat our patients' medical conditions, not to conduct assessments about a given patient's ability to work," said ACP President Jan K. Carney. The suit seeks to pause the rule before work requirements take effect in January 2027.

Key Takeaways:

• CMS's interim final rule requires medically frail enrollees to prove their condition prevents compliance with work requirements — a step critics say the statute does not authorize
• A 12-month claims data lookback period may exclude enrollees who would qualify under a 24-month window
• Clinicians may be forced to make work-capacity determinations, diverting time from patient care
• A similar lawsuit brought by 25 states was dismissed earlier this year, signaling an uphill legal battle ahead

Why it matters: With work requirements set to kick in January 2027, the outcome of this lawsuit could determine whether millions of chronically ill Americans keep or lose their Medicaid coverage.