A coalition of Medicaid enrollees, the city of Columbus, and provider groups including the American College of Physicians filed a lawsuit on September 18, 2026, challenging the Trump administration's narrow definition of "medical frailty" exemptions. The plaintiffs argue that the Centers for Medicare and Medicaid Services' rule violates the Administrative Procedure Act and oversteps the patient-provider relationship by forcing doctors to assess patients' ability to work. The administration defends the rule as a tool to combat program waste under the One Big Beautiful Bill Act.
September 2026 Lawsuit Details
- ▪A coalition of Medicaid enrollees, provider groups, and the city of Columbus, Ohio, filed a lawsuit on September 18, 2026, in the U.S. District Court for the District of Maryland challenging the Trump administration's medical-frailty Medicaid work-requirement exemptions
- ▪The lawsuit against CMS filed on September 18, 2026, asks the federal court to vacate the Centers for Medicare and Medicaid Services' rule on medical frailty, alleging it is arbitrary, capricious, contrary to law, and violates the Administrative Procedure Act
- ▪The plaintiffs in a lawsuit against CMS filed on September 18, 2026, include five individual Medicaid enrollees and six provider groups, including the American College of Physicians and the American Academy of Pediatrics
- ▪A lawsuit against CMS filed on September 18, 2026, alleges that Health Secretary Robert F. Kennedy Jr. and the Centers for Medicare and Medicaid Services improperly restricted which Medicaid beneficiaries can be excluded from work requirements due to medical frailty
The CMS Rule Requirements
- ▪The Centers for Medicare and Medicaid Services issued guidance allowing states to use a tiered system based on diagnostic coding and data sets to determine medical frailty exemptions.
- ▪The Centers for Medicare and Medicaid Services' rule limits the claims data used to prove medical frailty to a 12-month lookback period, which the plaintiffs in a lawsuit against CMS argue is too narrow compared to a 24-month period
- ▪The Centers for Medicare and Medicaid Services' rule requires Medicaid enrollees to demonstrate that their chronic health conditions prevent them from meeting work requirements to qualify for a medical frailty exemption.
The One Big Beautiful Bill Act
- ▪The One Big Beautiful Bill Act, enacted by Republican lawmakers in 2025, mandated the nation's first work requirements in the Medicaid program.
- ▪Under the One Big Beautiful Bill Act, Medicaid expansion beneficiaries must work or volunteer at least 80 hours per month, attend school part-time, or participate in job training starting in January
- ▪The One Big Beautiful Bill Act originally offered blanket exemptions from work requirements for individuals who are too medically frail.
Impact on Vulnerable Enrollees
- ▪Plaintiffs argue that the Centers for Medicare and Medicaid Services' medical frailty rule's onerous reporting and verification requirements will strip vulnerable enrollees of coverage and increase uncompensated care for healthcare providers
- ▪Advocacy groups and plaintiffs argue that the Centers for Medicare and Medicaid Services' narrow definition of medical frailty puts vulnerable enrollees with serious physical and mental health conditions at risk of losing Medicaid coverage.
State Legal Challenges
- ▪In a separate legal challenge, a federal judge in July 2026 denied a request by approximately two dozen states to block the Trump administration's "medically frail" definition rule.
- ▪In June 2026, twenty-five states and Washington, D.C., sued the Trump administration over its narrow definition of medically frail Medicaid enrollees.
Provider Objections
- ▪Provider groups, including the American College of Physicians, argue that the Centers for Medicare and Medicaid Services' rule issued in July oversteps the therapeutic patient-provider relationship and diverts clinical time by forcing clinicians to make work-capability assessments
- ▪America’s Physician Group argued that the Centers for Medicare and Medicaid Services' rule's narrow definition of medical frailty requires Medicaid enrollees to regularly meet with a provider to prove they are too frail to work
Debatable claims
- ▪Physicians should not be responsible for assessing Medicaid patients' ability to work
- ▪Medicaid exemptions should require proof that a medical condition prevents work
Story comments
Loading comments…