Clinton-Appointed Judge Strikes Trump’s ‘Medically Frail’ Test for Medicaid Work Rules
A federal judge in Boston on Thursday struck down the Trump administration’s narrow definition of who counts as “medically frail” under Medicaid’s new work requirements.
U.S. District Judge Richard Stearns, an appointee of President Bill Clinton, sided with 25 Democratic-led states and the District of Columbia, which sued in June over guidance from the Centers for Medicare and Medicaid Services, Politico reported.
Stearns said the guidance went beyond what Congress passed in the 2025 One Big Beautiful Bill Act and is “thus contrary to law.” He added, “There is an inherent public interest in ensuring that the government follows the law.”
The law says the medically frail category must include people who are blind or disabled, have substance use or disabling mental disorders, or have serious or complex medical conditions, according to the Associated Press.
CMS went further, requiring people in those categories to show their conditions also “significantly impair” their ability to meet the work requirements. That extra test is what Stearns threw out in his 16-page ruling.
“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.
Work Requirements Still Start Jan. 1
The ruling does not strike down the work requirements. Starting Jan. 1, 2027, adults ages 19 to 64 must log at least 80 hours a month of work or community engagement, or attend school at least half time, NBC News reported.
Stearns also upheld two other federal limits the states challenged. States must reject proof of medical frailty if the diagnosis is more than a year old, and they may accept only one self-attestation per continuous enrollment period.
“The government provided a non-frivolous rationale for adopting each provision and explained why it did not find the States’ concerns of disenrollment compelling,” he wrote.
The court vacated the frailty language, issued a permanent injunction and gave states a six-month stay of enforcement to absorb errors or delays from the changes, according to California Attorney General Rob Bonta’s office.
The attorneys general of California, Massachusetts and New Jersey led the challenge. CMS, headed by Administrator Mehmet Oz, did not immediately respond to NBC News’ request for comment.
During oral arguments last week, the states warned that without a ruling before January they would be “forced… to bear the costs and burdens of operationalizing this unlawful limitation.”
Stearns agreed the states faced “costly and intensive alterations to their eligibility verification systems.” Medicaid is jointly funded, with Washington covering at least half the cost of services.
Morgan Henderson, a Medicaid economist at The Hilltop Institute at the University of Maryland, Baltimore County, said the ruling will likely keep some enrollees covered. “Those individuals who would have lost coverage because they’re sick but they’re not quite sick enough, they might have their coverage preserved now,” he said.
The rules apply to adults covered through Medicaid expansion in most states. The administration can appeal Stearns’ decision to the 1st U.S. Circuit Court of Appeals.
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