25 states and D.C. file the first direct challenge to CMS-2454-IFC's medically-frail and related provisions
A coalition of 25 states and the District of Columbia, with California among the co-leads, filed Commonwealth of Massachusetts v. Oz, No. 1:26-cv-12962-RGS, on June 29, 2026. The filing challenged CMS-2454-IFC provisions governing the medically-frail exclusion and related verification and hardship rules.
The rule's additional medically-frail criterion asks whether a qualifying condition significantly impairs the ability to comply with community engagement; the complaint disputes that implementation. This filing did not decide the merits, a person's exclusion, or a number of FQHC patients who will lose coverage.
A June 29 Federal Register correction replaces 42 C.F.R. §§ 435.557–435.558. The California filing release also described August 31 as a notification deadline, but § 435.561(b)(1) and CMS Table 2 place initial outreach in September, August, or July according to the state's one-, two-, or three-month applicant lookback.
The responsible state Medicaid agency controls verification, official notice, and eligibility decisions. FQHC teams should use current federal and state instructions, avoid predicting a result, and keep disability, eligibility, work, income, immigration, and clinical records out of FQHC Talent.
Key takeaways
- The complaint challenges the rule's additional medically-frail criterion and related verification and hardship provisions; the filing itself decides none of those issues.
- The state Medicaid agency verifies exclusions and makes person-level eligibility decisions under the operative statute, the corrected rule, and its own implementation — a court filing changes none of that.
- Verify each state's selected applicant lookback: the rule places initial outreach in July, August, or September, not on one nationwide August 31 deadline.
Linked evidence
California Office of the Attorney GeneralSource packet
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FQHC Talent. (2026, June 29). 25 states and D.C. file the first direct challenge to CMS-2454-IFC's medically-frail and related provisions. Linked evidence: California Office of the Attorney General. Retrieved September 11, 2026, from https://www.fqhctalent.com/intel/states-lawsuit-medically-frail-exemption-work-req-ifr-june-2026
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