A federal judge ruled against the administration’s new rules regarding the medical frailty exemption as part of a multistate legal challenge.
The Trump administration will delay the enforcement of new Medicaid work requirements for six months, allowing states to opt out of enforcement until July 1 under a plan sent to state officials by the Centers for Medicare and Medicaid Services, according to The Washington Sun. While the work requirements technically take effect on January 1 under the One Big Beautiful Bill Act, the hold harmless window extends through June 30, 2027.
The domestic policy and tax law signed by President Donald Trump features work rules requiring certain Medicaid recipients to work, volunteer, or study at least 80 hours per month to maintain their healthcare coverage.
These requirements apply primarily to able-bodied Americans without young children enrolled in expanded Medicaid, a group totaling approximately 19 million people nationwide. Meanwhile, patients can secure exemptions from these obligations if they are pregnant, disabled, participating in substance abuse treatment programs, or serving as full-time caregivers for a family member.
Proponents of the policy argue that these work stipulations establish necessary incentives for low-income individuals to secure jobs or increase their working hours. Conversely, critics and opponents contend that the mandates act as a punitive barrier that will cause significant coverage losses.
Projections from the Congressional Budget Office indicate that about 5 million fewer people are expected to participate in Medicaid a decade from now due to the work conditions, with the vast majority of those individuals anticipated to remain uninsured.
Federal Court Strikes Down Medical Frailty Rule
The six-month delay follows a federal court ruling that struck down the administration’s interim final rule regarding medical exemptions. In the U.S. District Court for the District of Massachusetts, the court held that the definition of medical frailty was contrary to law, issued a permanent injunction, vacated the language, and granted a six-month stay of enforcement to handle implementation delays.
They were joined in the legal action by attorneys general representing Arizona, Colorado, Connecticut, Delaware, the District of Columbia, Hawai‘i, Illinois, Maine, Maryland, Michigan, Minnesota, Nevada, New Mexico, New York, North Carolina, Oregon, Rhode Island, Vermont, Virginia, Washington, and Wisconsin, along with the governors of Kentucky and Pennsylvania.
This win will help people with complex or serious medical conditions stay on Medicaid and keep their healthcare.
Attorney General Davenport
California Attorney General Bonta also welcomed the ruling regarding the exemptions.
“I will keep fighting to make sure red tape does not hurt those who are already struggling to stay well and maintain their dignity,” Attorney General Davenport said.
Today’s decision is a major victory that ensures that some of our most vulnerable residents are able to continue to access the healthcare they deserve.
Attorney General Bonta
States Prepare Automated Verification Systems During Enforcement Delay
Senior administration officials said that the enforcement delay provides crucial preparation time for state agencies that are currently “70% to 80% ready” to establish automated verification systems, The Washington Sun reported. States are required to submit flexibility requests in their mitigation plans by December 11. During the transitional hold harmless period, states can choose not to terminate coverage for noncompliant beneficiaries while still evaluating compliance to refine systems before mandatory enforcement begins.
CMS Administrator Mehmet Oz faced substantial pressure from state leaders and Democratic lawmakers to authorize an enforcement postponement as local agencies struggled to construct verification infrastructure. CMS released a letter outlining four critical steps for states: maximizing automated verification processes, providing timely notices to participants, conducting thorough end-to-end system tests, and coordinating closely with local community organizations.
CMS Deputy Administrator Dan Brillman outlined the federal agency’s implementation steps in an accompanying press release.
“If the state can use data to show that someone is working or qualifies for an exclusion, that person should not have to track down paperwork to prove it,” Brillman said, according to Nextgov.
Readers evaluating these policy developments should consult qualified legal or healthcare professionals regarding specific Medicaid eligibility rules, as administrative guidelines and ongoing litigation continue to evolve.
Earlier coverage: CMS Grants States Grace Period for Medicaid Work Requirements