NEW YORK – Democrats in 25 states and the District of Columbia on Monday sued the Trump administration over its recent guidance on new Medicaid work requirements, arguing the strict rules will prevent eligible Americans from accessing the care they need.
The attorneys general and governors who filed the lawsuit allege that an interim final rule released earlier this month by the Centers for Medicare and Medicaid Services oversteps the text of the law last summer that set in motion the changes to Medicaid.
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They claim the Republican administration’s narrow interpretation of parts of the statute, including new limits to a medical frailty exemption, will create harmful coverage barriers and chaos in states that have been rushing to implement new systems by the January deadline.
“Added administrative burdens will cause individuals who are eligible for Medicaid to lose or be denied coverage,” the plaintiffs write. “People with disabilities, patients in the middle of cancer treatment, or those struggling with another serious or complex health condition, shouldn’t be at risk of losing the care that helps maintain their health.”
Spokespeople for the U.S. Department of Health and Human Services and CMS, the agencies named in the lawsuit, didn’t immediately respond to a request for comment. The Trump administration has promoted the new rules as commonsense measures to eliminate government freeloading and preserve benefits for those who need them most.
The new Medicaid restrictions, which Democrats have criticized, were part of Trump’s big tax and policy law in 2025. The change affects those covered through an expansion in most states that gave more lower-income people access to the government’s safety net healthcare program.
Starting Jan. 1, expansion enrollees age 19 to 64 will have to show that they work or do community service at least 80 hours a month or are in school at least half the time. There are exceptions for those considered medically frail or in addiction treatment programs, among others.
This month’s announcement from CMS caught states off guard with a new definition of medical frailty. The law had said medically frail people include those who have substance use disorders, disabilities or serious medical conditions. But the CMS rule went further, saying someone’s condition must “significantly impair” their ability to work, volunteer or attend school at the rates required in the law for them to be granted an exemption.
In 2027 and once in 2028, the patient can attest that they meet this definition. But when they try to renew coverage in 2028, they’ll need to prove it. Health analysts and state Medicaid directors have said they aren’t clear on what existing documentation could prove that point.
In the lawsuit, states allege that this change came “contrary to months of regular communications with CMS and preliminary guidance materials upon which Plaintiff States based their implementation plans.” They say CMS has still not provided states with enough clarity on how they can update their systems appropriately.
Kinda Serafi, a partner at the legal and consulting firm Manatt Health who is working with states to make the changes, said the administration “moved the goalposts” with its rule on medical frailty.
“By going beyond the clear language of the statute, CMS opened the door to this court challenge,” she said.
New York Attorney General Letitia James, one of the Democrats suing the administration, said the new rule puts thousands of her state's residents at risk.
“New Yorkers who are battling cancer, living with a disability, managing a serious mental health condition, or recovering from addiction should be able to get the health care they need without being buried in paperwork,” she said in a statement.