What Is This New Development?
Today, October 29, 2026, a federal judge agreed with a coalition of 25 states and the District of Columbia in their lawsuit challenging the Centers for Medicare and Medicaid Services (CMS) definition of “medical frailty” in CMS’ work requirements interim final rule.
The states sued CMS Administrator Mehmet Oz (MA v. Oz) because CMS’s definition of “medical frailty” in their interim final rule on Medicaid work and community engagement requirements was much stricter than the definition in the budget bill law passed by Congress in July 2025, H.R. 1, which cut more than $1 trillion from Medicaid.
By establishing an even stricter definition than the law requires, the federal government’s proposed policy ensured people with disabilities and chronic illnesses would lose their Medicaid coverage despite being exempt from CMS’s work requirements as Congress wrote them. Today, a federal judge said CMS could not propose a definition stricter than Congress intended.
What Did The Law Say Before Today?
The strict CMS definition of medical frailty would require a person to demonstrate both that they are “medically frail” and also that being medically frail “significantly impairs” them from being able to work. It had a lot of vague language that could be interpreted very differently from one state to another.
The CMS definition also prevented “medically frail” people from being able to establish their medical frailty through self-certification – requiring even further administrative burden, access to doctors, and fees. AAPD and many other disability advocacy organizations advocated in our comments on CMS’s proposal that self-attestation should be allowed.
What Does The Ruling Mean For Medicaid Work Requirements and People with Disabilities?
As a result of the ruling, effective immediately nationwide, the “medical frailty” exemption for Medicaid work requirements goes back to its original definition as Congress wrote it. Today’s ruling does not end work requirements entirely. It eliminates some harmful aspects of how work requirements are administered.
Another aspect of the judge’s decision nods towards the significant administrative, medical, and financial burden caused by implementing work requirements. The court ordered states to wait for at least six months after January 1, 2027 (when the rules go into effect) before cancelling the health insurance of any person claiming they meet the requirements for a medical exemption. This will give Medicaid recipients who might qualify for an exemption time to gather and submit the many documents and verifications required to prove exemption from work requirements.
Take Action
Even with this ruling, many Americans with disabilities will lose access to the health care and the services they need to survive because of work requirements. Still, this good Medicaid news is a necessary reminder of the power of our community’s extensive advocacy to protect Medicaid.
States are currently in the process of determining how they will administer this new policy – our advocacy within our states is essential right now. AAPD will continue to advocate to reduce the harm caused by Medicaid work requirements as much as possible.
Navigating Medicaid work and community engagement requirements can be overwhelming and complex. AAPD’s explainers and resources can help: check out our June FAQ on the new rules, an ASL version of the June FAQ, and our Plain Language overview of Medicaid work requirements.
Keep coming back to AAPD’s Medicaid Defense Hub and make sure you’re registered for our email list to ensure you receive additional resources we’ll be sharing through the end of the year.
Finally, if you can, please donate to AAPD so we can continue to produce these resources and make them accessible.