AMA files amicus brief opposing narrow medical frailty standard for Medicaid work requirements
On July 21, 2026, the AMA and the Massachusetts Medical Society filed an amicus brief (PDF) supporting 26 plaintiff states challenging the recent CMS interim final rule that significantly narrows the definition of "medical frailty" for purposes of Medicaid work requirements.
Public Law 119–21 (known as the One Big Beautiful Bill Act or H.R. 1) established new Medicaid community engagement requirements for certain adults as a condition of Medicaid eligibility. Recognizing that some individuals should not be subject to these requirements, Congress excepted several categories of individuals, including those who are considered medically frail, defined as individuals who are blind or disabled or with a substance use disorder, disabling mental disorder, a serious physical, intellectual, or developmental disability, or a serious or complex medical condition.
The interim final rule, issued on June 1, 2026, requires that, to qualify for an exception from work requirements on the basis of medically frailty, an individual must not only have a qualifying health condition but also demonstrate that the condition significantly impairs their ability to comply with the work requirements. The plaintiff states argue that this additional impairment requirement is not found in the statute and unlawfully creates new barriers to Medicaid coverage.
In the amicus brief, the AMA argues that the rule is inconsistent with Congress' intent to protect medically frail individuals and imposes an unlawful standard that will make it harder for eligible patients to qualify for the exemption. The brief explains that the rule would require physicians to make impairment determinations that lack clear clinical standards, increase administrative burdens on physician practices, disrupt continuity of care, and place medically frail patients at risk of losing Medicaid coverage for procedural reasons rather than because they fail to meet the statutory definition of medical frailty. The brief also supports the states' request for preliminary injunctive relief, arguing that without court intervention, states would be required to implement a standard that could jeopardize Medicaid coverage for vulnerable patients.
The AMA has long opposed work requirements as a condition of Medicaid eligibility, and new policy adopted at the 2026 Annual Meeting of the AMA House of Delegates advocates that medical frailty exceptions should be clinically appropriate, protective of patients with serious health conditions, and implemented in a manner that minimizes unnecessary administrative burdens on patients and physicians.
More articles in this issue
- Top stories of Advocacy Update: July 2026
- July 31, 2026: National Advocacy Update
- July 31, 2026: State Advocacy Update
