Physician organizations file amicus brief supporting challenge to Medicaid work rule
The AMA, joined by the Maryland State Medical Society (MedChi) and several national physician organizations, filed an amicus brief (PDF) in Taylor v. Kennedy supporting plaintiffs’ motion for summary judgment in a challenge to federal Medicaid work requirement regulations.
Filed in the U.S. District Court for the District of Maryland, the brief argues that the Centers for Medicare & Medicaid Services (CMS) exceeded its statutory authority by narrowing the medical frailty exemption established by Congress. The physician organizations contend that the rule unlawfully adds a requirement not found in the statute by requiring individuals with qualifying medical conditions to prove that those conditions “significantly impair” their ability to comply with work requirements.
According to the brief, Congress expressly excluded medically frail individuals from Medicaid work requirements under H.R. 1, including people with substance use disorders and those with serious or complex medical conditions. The amici argue that CMS cannot rewrite that protection by converting it from a medical-status exemption into an ability-to-work test. The brief also opposes CMS restrictions on states’ ability to accept self-attestation of medical frailty. The physician organizations argue that those limits will increase paperwork burdens, make it harder for eligible patients to maintain coverage, and create avoidable barriers to care.
“People living with serious or complex medical conditions should not lose their health coverage because of unnecessary administrative barriers,” AMA President Willie Underwood III, MD, MSc, MPH, said in an AMA press release. “Losing Medicaid coverage can mean losing access to essential medications, interrupting ongoing treatment, and putting patients’ health at risk.”
The amici emphasize that Medicaid expansion provides a critical source of coverage for about 20 million Americans. The brief cites research linking Medicaid expansion to improved access to care and lower mortality among patients with serious conditions, including cancer, cardiovascular disease, opioid use disorder, and liver disease. It warns that unnecessary coverage disruptions could undermine those gains and place vulnerable patients at greater risk.
The filing also highlights the practical burden the CMS rule could place on physicians. Because Medicaid claims and encounter data often document diagnoses and treatment, but not a patient’s functional ability to satisfy work requirements, the rule could force treating physicians to make high-stakes eligibility assessments without clear standards or validated criteria. The brief argues that this added administrative work would divert time and resources away from patient care and could strain the patient-physician relationship.
This amicus brief also follows the AMA’s earlier amicus advocacy in a separate challenge to the same Medicaid work requirements rule. As described in a prior Advocacy Update, the AMA and the Massachusetts Medical Society filed an amicus brief (PDF) in July supporting 25 states’ and the District of Columbia’s request for a preliminary injunction in Massachusetts v. Oz, and in September, the AMA, the Massachusetts Medical Society, and nine national medical specialty societies filed a second amicus brief (PDF) supporting the plaintiff states in their motion for summary judgment. Those briefs likewise argued that CMS exceeded its authority by narrowing the medical frailty standard and restricting states’ use of self-attestation, creating unnecessary administrative burdens, and increasing the risk that eligible patients would lose coverage for procedural reasons.
In addition to the AMA and MedChi, the brief in Taylor v. Kennedy was joined by the American Academy of Family Physicians, American Academy of Hospice and Palliative Medicine, American College of Emergency Physicians, American College of Obstetricians & Gynecologists, American Society of Addiction Medicine, Association for Clinical Oncology, and American Thoracic Society. The organizations ask the court to grant plaintiffs’ motion for summary judgment and vacate the challenged provisions of the rule, including the narrowed definition of medical frailty and the limits on use of self-attestation.
More articles in this issue
- Top stories of Advocacy Update: October 2026
- Oct. 30, 2026: National Advocacy Update
- Oct. 30, 2026: State Advocacy Update
