CHICAGO — The American Medical Association (AMA) and the Maryland State Medical Society (MedChi), joined by several national physician organizations, filed an amicus brief in Taylor v. Kennedy, a new lawsuit challenging federal regulations that make it harder for people with serious or complex medical conditions to qualify for an exemption from Medicaid work requirements.
The brief, filed in the U.S. District Court for the District of Maryland, supports the plaintiffs’ motion for summary judgment and argues that the Centers for Medicare & Medicaid Services (CMS) exceeded its statutory authority by imposing narrow restrictions on the medical frailty exemption established by Congress under H.R. 1, the One Big Beautiful Bill Act.
Under the law, individuals who are medically frail, including those with substance use disorders or serious or complex medical conditions, are expressly excluded from Medicaid work requirements. However, CMS regulations require individuals to demonstrate that their medical condition significantly impairs their ability to comply with those requirements, an additional standard the physician organizations maintain is not authorized by the statute.
The brief also argues that restrictions on states’ ability to accept individuals’ self-attestation of medical frailty could force patients to obtain additional documentation to maintain coverage, increasing administrative burdens and the risk that eligible individuals will lose coverage.
“People living with serious or complex medical conditions should not lose their health coverage because of unnecessary administrative barriers,” said AMA President Willie Underwood III MD, MSc, MPH. “Losing Medicaid coverage can mean losing access to essential medications, interrupting ongoing treatment, and putting patients’ health at risk.”
Medicaid expansion provides health coverage to approximately 20 million Americans. Research cited in the brief links Medicaid expansion to improved access to treatment and lower mortality among people with serious conditions, including cancer and cardiovascular disease. Disruptions in coverage can jeopardize these gains, interrupting treatment and continuity of care.
The brief warns that CMS’s requirements could also leave physicians responsible for assessing patients’ eligibility for medical frailty exemptions without clear clinical standards, adding administrative work that could divert time from patient care and strain physician-patient relationships.
In addition to asking the court to grant the plaintiffs’ motion for summary judgment, the AMA and MedChi urge the court to vacate the challenged provisions of the federal regulations. Joining AMA and MedChi in the brief are 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 argue that Congress intended the medical frailty exemption to protect people with qualifying medical conditions—without requiring them to separately demonstrate that those conditions impair their ability to comply with work requirements.
The brief in Taylor v. Kennedy is the latest example of AMA support for legal challenges to the CMS rule. Earlier this summer, 25 states and the District of Columbia filed Massachusetts v. Oz, challenging portions of the rule. The AMA, the Massachusetts Medical Society, and other physician organizations filed amicus briefs supporting the states’ request for a preliminary injunction and motion for summary judgment. The AMA continues to urge implementation of requirements in a manner that protects eligible patients from avoidable coverage losses and minimizes unnecessary administrative burdens on patients and physicians.
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