Federal judge strikes down CMS rule that would have made it harder for sick Medicaid enrollees to get work requirement exemptions

A federal judge has struck down a CMS rule that would have required Medicaid beneficiaries classified as "medically frail" to prove their condition significantly impairs their ability to meet new work requirements. U.S. District Judge Richard G. Stearns ruled that CMS "lacked authority" to impose this additional impairment test on individuals who already fall within the five statutory medical frailty categories — which include blindness, substance use disorders, disabling mental disorders, physical or intellectual disabilities, and serious or complex medical conditions.

The ruling came in Commonwealth of Massachusetts v. Oz, a case brought by 25 states and Washington, D.C., and supported by an amicus brief from the AMA and 10 other medical societies. The broader Medicaid work requirements — requiring eligible adults aged 19–64 to engage in 80 hours of qualifying activity per month — remain intact and are still set to take effect Jan. 1, 2027.

Key Takeaways:

• Medically frail Medicaid enrollees no longer need to prove their condition prevents them from working — being in a qualifying category is sufficient for exemption
• States can still require that proof of medical frailty be no older than 12 months, and may limit self-attestation to once per continuous enrollment period
• Clinicians had raised concerns that the CMS rule would have forced them to assess patients' work capacity, diverting time from patient care

Why it matters: The ruling removes a significant bureaucratic barrier for some of Medicaid's most vulnerable enrollees. As the AMA noted, symptoms fluctuate and treatment can be debilitating — forcing patients to repeatedly prove their limitations could have led to wrongful disenrollment and strained the physician-patient relationship.