Judge Strikes Down Trump Administration’s Definition of Medical Frailty

November 5, 2026

On October 29, a federal judge ruled that the Centers for Medicare and Medicaid Services (CMS) exceeded its authority when it restricted the definition of medical frailty – for the purpose of Medicaid work requirement exemptions– beyond the language in statute H.R. 1 (i.e., the One Big Beautiful Bill Act). 

The successful plaintiffs in the case include 24 states, including Minnesota. 

Effective January 1, 2027, H.R. 1 imposes Medicaid work requirements on childless adults enrolled as part of a state’s ACA Medicaid expansion, which includes Minnesota. However, H.R. 1 exempts those who are “medically frail or otherwise [have] special needs.” The law explicitly requires that the exemption include any individual: 

• who is blind or disabled; 

• with a substance use disorder; 

• with a disabling mental disorder; 

• with a physical, intellectual or developmental disability that significantly impairs their ability to perform one or more activities of daily living or; 

• with a serious or complex medical condition. 

H.R. 1 further directs CMS to provide details on the implementation of work requirements and medical exemptions.  

On June 1, 2026, CMS released an interim final rule, which sought to prohibit states from issuing medical frailty exemptions based on diagnoses alone. In addition to the presence of a diagnosis, the interim rule sought to require states to prove that the severity of the diagnosis impedes the person’s ability to meet the work requirements.  

The October 29 ruling determined that the language in H.R. 1 authorized CMS to require proof of diagnosis only. The additional requirement in the interim rule to report severity of diagnosis and impediment, therefore, is unlawful. 

The Trump administration may appeal the decision, although the timeline for continued litigation is unclear given the looming January 1 effective date.  

Absent other sources of data available to states, individuals can self-attest medical frailty or other work requirement exclusions for the entirety of 2027. In 2028, individuals may self-attest once per continuous Medicaid enrollment period, but must then provide proof of eligible diagnosis and, pending a final court decision, proof of diagnosis severity, and impediment. 

The MMA will continue to inform its members about Medicaid work requirements and medical frailty exemptions. Please contact the MMA at mma@mnmed.org with questions.