AMA and Federation partners support challenge to narrow Medicaid work requirements standard
On Sept. 10, the AMA, Massachusetts Medical Society and nine national medical specialty societies filed an amicus brief (PDF) supporting 25 states and the District of Columbia in their motion for summary judgment challenging key provisions of the CMS interim final rule implementing new 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. A CMS interim final rule, issued on June 3, 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 brief argues that CMS exceeded its authority by requiring individuals with qualifying conditions to also demonstrate that their condition significantly impairs their ability to comply with the work requirements. Congress imposed no such impairment standard across all five categories of medical frailty, including individuals with a substance use disorder or serious or complex medical condition.
The brief also challenges CMS’ restriction on states’ use of self-attestation beginning in 2028. The organizations explain that the challenged provisions will require many patients to repeatedly obtain documentation, impose substantial administrative burdens on physicians, disrupt the patient-physician relationship and cause eligible individuals to lose coverage for procedural reasons.
On July 21, the AMA and the Massachusetts Medical Society filed an earlier amicus brief (PDF) supporting the states’ request for a preliminary injunction. The court subsequently denied that request but established an expedited schedule to consider the merits of the case at summary judgment. The district court is expected to rule before the Jan. 1, 2027, implementation date. The new brief urges the court to grant summary judgment and vacate both the narrowed medical frailty definition and the limitation on states’ use of self-attestation.
The AMA has long opposed work requirements as a condition of Medicaid eligibility, and 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: September 2026
- Sept. 18, 2026: National Advocacy Update
- Sept. 18, 2026: State Advocacy Update
