By Paige Minemyer / October 29, 2026
UPDATED: Oct. 29 at 1:30 p.m. ET
A Massachusetts judge has sided with a coalition of states in an ongoing lawsuit over the rollout of Medicaid work requirements, and rejected the Trump administration's definition of "medical frailty" for critical exemptions.
Judge Richard Stearns ruled Thursday that a regulation issued over the summer that aimed to offer guardrails to the implementation of the work requirements unlawfully limited the group of people who would qualify as "medically frail" and would thus be exempted.
In the rule, the Centers for Medicare & Medicaid Services said that the frailty exemption would apply when a "physical, mental, or other behavioral health condition significantly impairs the individual’s ability to comply with the community engagement requirement."
This runs afoul of existing law, as there are individuals in five frailty categories established by Congress who may not qualify for the exemption under CMS' definition, Stearns said.
"Because enforcement of an unlawful definition of 'medically frail' may lead to the disenrollment of otherwise eligible vulnerable individuals relying on Medicaid coverage for continuity of care, the States (and public) face potential for great hardship in the absence of an injunction," Stearns wrote. "The court accordingly will issue the permanent injunction requested by the States."
Stearns' ruling isn't a complete win for the state plaintiffs, as he allowed other challenged provisions to stand. Under the order, he determined that CMS should offer states a six-month stay of enforcement on frailty determinations given the short timeline ahead of the work requirements' rollout.
States are down to the wire in implementing the requirements, which were established as part of the massive H.R. 1 legislation in the summer of 2025. The eligibility determinations must be in place nationally on Jan. 1, and experts have warned that the added administrative burden is likely to lead millions to fall out of the Medicaid coverage rolls.
UPDATED: July 30 at 3 p.m. ET
A federal judge has rejected a request from 26 states for a preliminary injunction in the Trump administration's rollout of work requirements in Medicaid.
The Centers for Medicare & Medicaid Services finalized implementation guidelines for states in June, with the eligibility requirements set to take effect on Jan. 1. States have until Aug. 31 to communicate with enrollees about the impacts of the changes.
In the lawsuit, the states argued that they do not have the resources necessary to meet the timelines that CMS established in June. They also pushed back on multiple provisions of the final rule, including regulators ultimate definition of medical frailty, which will have a significant impact on who qualifies for exemptions to the requirements.
In an order issued Wednesday, Massachusetts District Judge Richard Stearns wrote that the states did not prove that establishing the systems necessary to make the eligibility determinations would cause them irreparable harm, as CMS said it would reimburse them for 90% of the costs for setting up those mechanisms.
However, he said that the order does not reflect the court's opinion on the merits of the broader litigation, which challenge provisions of the rule under the Administrative Procedure Act. Making a determination on that, as it questions whether officials hewed closely to Congressional intent in regulating the rollout of the requirements, requires a more complete picture.
"These are determinations that, in the view of the court, should be made on a developed record of the kind that informs a court’s decision at the summary judgment stage of a case," wrote Stearns.
PUBLISHED: June 30 at 4:20 p.m. ET
A coalition of 26 states is suing the Trump administration over its rollout of Medicaid work requirements.
In the lawsuit—jointly led by California Attorney General Rob Bonta, Massachusetts Attorney General Andrea Joy Campbell, and New Jersey Attorney General Jennifer Davenport—the states seek to challenge provisions in the Centers for Medicare & Medicaid Services' recently-finalized rule establishing guardrails the work requirements implementation.
A key pillar of that rule is the agency's definition of who would be considered "medically frail," and thus qualify for an exemption to the requirements. The states argue that the newly established definition will make it far harder for people who may need an exemption to obtain one.
In addition, under the rule, states are now asked to notify Medicaid enrollees of the incoming work requirements by Aug. 31, though the requirements will not be in place until Jan. 1. The suing states argue that this new window leaves them with insufficient time to reach out to members.
The lawsuit is asking the courts to block or strike down these parts of the rule, as they have already made strides toward implementing the work requirements based on previous CMS guidance and the One Big Beautiful Bill Act, which established the national mandate for the eligibility requirements.
If states fail to comply with the final rule, they face significant potential fines, the suing states said.
In a press release from Massachusetts Attorney General Campbell's office, the state notes that officials raised concerns with CMS about the impact of sudden changes to the timeline, which could lead to disruptions in implementation.
In addition, the states argue that the work requirements violate the Administrative Procedure Act, as there is "substantial" evidence that the administrative barriers can lead people who are eligible to lose coverage given the burden in keeping up with the requirements.
“The Trump Administration’s attempt to impose new, burdensome requirements on Medicaid recipients threatens access to healthcare for our most vulnerable residents and families,” said Campbell in a press release. “Congress made clear that people with serious medical conditions should not lose coverage. We are asking the court to block these unlawful provisions to protect Medicaid recipients and prevent needless strain on Massachusetts’ healthcare system.”
Beyond California, Massachusetts and New Jersey, other states signed on to the lawsuit include Arizona, Colorado, Connecticut, Delaware, District of Columbia, Hawaii, Illinois, Kentucky, Maine, Maryland, Michigan, Minnesota, Nevada, New Mexico, New York, North Carolina, Oregon, Pennsylvania, Rhode Island, Vermont, Virginia, Washington and Wisconsin.