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Legislation

25 states and D.C. Challenge CMS medically frail rules in court

National

Issue

Medicaid work-requirement implementationTaking effect

Next: · IHAWP community-engagement requirements begin

On June 29, 2026, 25 states and the District of Columbia, with California as a co-lead, filed Commonwealth of Massachusetts v. Oz. The suit challenges CMS rules on the medically frail exclusion from work requirements and related verification and hardship rules.

The filing does not decide the case, and state Medicaid agencies still make each eligibility decision.

Key points

  • 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 still checks exclusions and decides each person's eligibility under the law and the corrected rule.
  • Check your state's lookback period, which puts initial outreach in July, August, or September.

Sources for this story

California Office of the Attorney General

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Cite this analysis

FQHC Talent. (2026, June 29). 25 states and D.C. Challenge CMS medically frail rules in court. Source: California Office of the Attorney General. Retrieved November 11, 2026, from https://www.fqhctalent.com/intel/states-lawsuit-medically-frail-exemption-work-req-ifr-june-2026