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Federal Judge Strikes CMS Strict Definition of Medical Frailty for Medicaid Work Requirement

Posted on October 30, 2026

Yesterday, October 29, 2026, a federal judge in Massachusetts struck down the Center for Medicare and Medicaid Services' new definition of medical frailty in their rules implementing the Medicaid cuts passed by Congress last year in H.R.1. The judge found that the CMS rule contained a stricter definition of medical frailty than was included in H.R.1 and said that the CMS definition unlawfully went beyond what Congress intended. The stricken CMS classification of medical frailty would have required that Medicaid recipients prove that they were both medically frail and that their frailty "substantially impaired" their ability to comply with the work requirements. This extra burden of proving that you are substantially unable to comply with the requirements would have been a strict administrative barrier that Medicaid beneficiaries would have had to meet.
 
Keep in mind, CMS could still appeal this ruling to a higher court. Additionally, the broader work requirement rule is still intact, with the judge upholding other controversial requirements contained in the rule. However, ACB celebrates this small victory as it likely means fewer eligible individuals will improperly lose their Medicaid coverage when these rules start to go into effect.