On October 29, 2026, a federal district court in Massachusetts struck down part of CMS’s Medicaid community engagement rule, ruling that CMS exceeded its statutory authority by narrowing the definition of “medically frail” individuals who may qualify for an exemption from the new requirements. The court’s decision to set aside the challenged requirement applies nationwide, while its injunction against enforcement applies only to the 25 plaintiff states and the District of Columbia. The court left the remainder of the rule in place, and the January 1, 2027 implementation date remains unchanged under the current ruling.
The Court Rejects CMS’s Medical Frailty Standard
Under the One Big Beautiful Bill Act, certain Medicaid enrollees must complete 80 hours per month of qualifying community engagement activities (also referred to as work requirements) to maintain coverage, subject to statutory exceptions. One exception applies to individuals who are medically frail or have special medical needs. In its June 2026 interim final rule, CMS required individuals in the covered categories to also demonstrate that their physical, mental, or other behavioral health condition significantly impairs their ability to comply with the community engagement requirement.
The plaintiff states challenged this additional condition, arguing that CMS had improperly narrowed the statutory exception. The U.S. District Court for the District of Massachusetts agreed, holding that CMS lacked statutory authority to impose the additional impairment requirement. The court set aside the challenged requirement and separately enjoined the federal government from implementing or enforcing it against the plaintiff states. The court also prohibited the federal government from penalizing those states for implementation errors or delays for six months following the October 29 order.
Other Restrictions Remain in Place
The ruling was not a wholesale rejection of CMS’s medical-frailty policies. The court upheld two other challenged provisions: a restriction on relying on diagnoses more than 12 months old to establish medical frailty and a limitation on individuals’ ability to self-attest to their medical frailty more than once during a continuous period of enrollment. The court also left the remainder of the community engagement rule in place. Accordingly, the decision does not eliminate the work requirements or formally postpone their January 1, 2027 implementation date.
Implications for States and Stakeholders
Because the challenged requirement was set aside nationwide, the decision has implications beyond the plaintiff states. Medicaid managed care organizations, providers, and other stakeholders should monitor CMS guidance and state implementation decisions as the January 1 deadline approaches. In particular, stakeholders should distinguish between the medical-frailty standard invalidated by the court and the other verification requirements that remain in effect.
Groom’s Health Services practice will continue to monitor developments affecting Medicaid community engagement requirements and their implementation.
Read the decision here.
