Federal rule unlawfully narrows protections for people who are medically frail or have special medical needs
BALTIMORE, MARYLAND – Today, five Medicaid enrollees, American College of Physicians, American Academy of Pediatrics, Society for Adolescent Health and Medicine, Doctors for America, New Hampshire Medical Society, New Hampshire Chapter of the American Academy of Pediatrics, and the City of Columbus filed a lawsuit challenging a federal rule that threatens Medicaid coverage for people with serious and chronic health conditions.
Access court documents in Taylor et al. v. Kennedy, Jr. et al
The plaintiffs are represented by the National Health Law Program and Democracy Forward. Individual Medicaid enrollees are also represented by state-based legal aid and advocacy organizations including Legal Council for Health Justice (Illinois), Legal Aid of Western Missouri, and Indiana Justice Project.
The lawsuit challenges key provisions of an interim final rule implementing the One Big Beautiful Bill Act’s new Medicaid work requirements. The rule narrowly defines who qualifies for the law’s medical frailty exclusion, putting people with serious physical and mental health conditions at risk of losing Medicaid because of new reporting and verification requirements, even though Congress categorically excluded medically frail people from the requirements.
See our Case Explainer
“Congress created the medical frailty exclusion to protect people with serious health needs, but the administration’s rule turns that protection into yet another obstacle people must overcome,” said Jane Perkins, Litigation Director at the National Health Law Program. “The statute does not require medically frail people to prove that their conditions are so debilitating that they cannot meet the work requirement. The statute exempts the medically frail from work requirements and does not authorize CMS to re-introduce it through the backdoor with the new rule. This rule puts access to care and, in some cases, people’s lives at risk.”
People living with diabetes, cancer, HIV, substance use disorders, disabling mental health conditions, and other serious or complex medical conditions rely on continuous access to physicians, medications, and treatments. Interruptions in Medicaid coverage can cause people to miss appointments, lose access to medication, experience worsening health, and require more intensive and costly care. Losing coverage can also make it harder–not easier–for people to remain healthy enough to work.
The rule requires people with covered physical, mental, or behavioral health conditions to show that their condition significantly impairs their ability to comply with the work requirement. That additional restriction is not found in the statute and excludes people who have serious health care needs but may not be able to demonstrate the particular form or degree of impairment demanded by the rule.
“Implementing a de facto work requirement on medically frail people is a heartless attempt by the Trump-Vance administration to kick those who are most in need of support and betrays Congress’ clear instruction to protect people in need,” said Skye Perryman, President and CEO of Democracy Forward. “We are honored to work with this coalition to protect those who need essential healthcare coverage.”
“Medicaid work requirements do not help people find or keep jobs. They put people’s health care at risk,” said Jennifer Cannistra, Executive Director of the National Health Law Program. “Every additional verification requirement, form, and submission creates another opportunity for an error or misunderstanding to cost someone their coverage. Past experience shows that many of the people who lose Medicaid are already working or qualify for an exclusion. They lose coverage because of paperwork and administrative barriers, not because they are ineligible.”
The complaint is available HERE.
Background
The Interim Final Rule implementing the 2025 One Big Beautiful Bill Act requires adults in the 40 states and District of Columbia who receive Medicaid through the ACA Medicaid expansion to demonstrate that they have completed a specified number of hours of work or other qualifying activities to obtain or maintain Medicaid coverage. Congress categorically excluded several groups from these requirements, including people who are medically frail or otherwise have special medical needs.
The Administration’s rule narrows those protections by adding a back-door work requirement that requires people to establish not only that they are medically frail but also that their condition significantly impairs their ability to meet the work requirements. As a result, people whom Congress intended to protect would be subjected to work and reporting requirements and lose Medicaid coverage.
The case is Taylor et al. v. Kennedy, Jr. et al, filed in the U.S. District Court for the District of Maryland. The plaintiffs are represented by the National Health Law Program and Democracy Forward.
Perspective of Legal Aid and Advocacy Counsel and Organizational Plaintiffs
“Medicaid is a lifeline, and we will continue to fight policies that put paperwork and bureaucracy between people and the care they need” said Julie Justicz, Executive Director, Legal Council for Health Justice
“For our client and thousands of Missourians, Medicaid is what keeps their health, and their lives, stable. Losing it doesn’t just interrupt care. It takes away the security they build everything else on,” said Amber Christ, Executive Director of Legal Aid of Western Missouri. “This rule makes them prove not just that they are medically frail, but that they cannot work, piling on even more paperwork and process. People won’t lose their coverage because they are ineligible. They’ll lose it over a missing form or a doctor’s letter that never arrived.”
“Medicaid helps thousands of Indiana residents, providing critical life sustaining healthcare. We are honored to help ensure continued access to health coverage with as few paperwork barriers as possible,” said Adam Mueller, Executive Director, Indiana Justice Project.
Physicians and other health care professionals see firsthand what happens when patients lose coverage and treatment is interrupted. The medical organizations bringing this case represent pediatricians, internal medicine physicians, and other health care professionals who care for people covered by Medicaid. They are challenging the rule because it threatens their patients’ access to essential care and interferes with their ability to provide consistent, effective treatment.
“When adults lose health care coverage, children are more likely to lose coverage, and we know even short disruptions in children’s coverage can have serious consequences for their overall health, from missed appointments to unfilled prescriptions to trips to the emergency department,” said Andrew D. Racine, MD, PhD, FAAP, President of the American Academy of Pediatrics. “This new rule needlessly puts the health of families and children at risk. Our federal leaders should be advancing policies that make accessing health care as seamless and efficient as possible for families – this rule does the opposite.”
“The American College of Physicians is deeply concerned about the impact of work requirements on Medicaid patients. Medicaid beneficiaries are, by definition, individuals with limited incomes and resources. We should not and must not be implementing policies that place this already vulnerable population at increased risk of interrupted treatment, disrupted coverage, or losing healthcare access altogether. As physicians, we are trained to diagnose and treat our patients’ medical conditions, not to conduct assessments about a given patient’s ability to work. Forcing doctors into the position of making these assessments diverts their time away from providing needed and life-saving health care to patients. Even worse, this puts patients with serious and chronic health conditions health at risk, from a sudden and dramatic loss of needed health care,” said Jan K. Carney, MD, MPH, MACP, President of ACP.
“Access to health care is a human right for all, including adolescents and young adults, and public funding is what makes that right real for low-income and vulnerable youth. SAHM is joining this lawsuit because our members cannot stand by while policy decisions jeopardize our patients’ health, education, and future well-being,” said Ryan Norton, Executive Director of the Society for Adolescent Health and Medicine.
“Physicians know that continuity of care can be the difference between a manageable health condition and a medical crisis and bankruptcy. This rule puts unnecessary bureaucratic barriers between patients and the care they need, including people living with serious and chronic health conditions whom Congress specifically intended to protect,” said Meenakshi Bewtra, MD, PhD, MPH, President of Doctors for America. “Patients should not lose their health coverage because they could not navigate another form, verification requirement, or administrative hurdle. Prior attempts at such requirements have resulted in tens of thousands of people losing necessary medical care simply because of the administrative burden. We are a great enough country to provide healthcare especially to our most vulnerable. Doctors for America is joining this challenge because Medicaid policy should help patients stay healthy and connected to care, not create new pathways for eligible people to lose coverage.”
“Creating barriers to healthcare coverage for the most vulnerable needlessly puts people’s lives at risk and inevitably drives up the cost of care for everyone,” said Columbus City Attorney Zach Klein. “These are folks who should be focused on getting the help and care they desperately need, not overcoming even more obstacles. We cannot allow the Trump administration to continue to chip away at Americans’ access to quality, affordable healthcare.”
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The National Health Law Program protects and improves access to health care for low-income and underserved people and works to advance health equity. NHeLP advocates, educates, and litigates at the federal and state levels. www.healthlaw.org
Democracy Forward Foundation is a national legal organization that advances democracy and social progress through litigation, policy, public education, and regulatory engagement. For more information, please visit www.democracyforward.org.
Legal Aid of Western Missouri provides free civil legal assistance to people with limited resources across 40 Missouri counties. We help people stay in their homes, escape domestic violence, and secure the benefits and stability they are entitled to under the law. www.lawmo.org
The Indiana Justice Project is a non-partisan, non-profit legal advocacy organization that uses all available legal tools to ensure equal justice and opportunity for all Hoosiers. We focus on health, housing, and food insecurity. https://www.indianajusticeproject.org/
Legal Council for Health Justice (LCHJ) is a Chicago nonprofit that uses the power of law and policy to advance health justice by protecting the rights of people with disabilities, advocating for children and families with complex health and social needs, and removing legal barriers to healthcare, education, and economic opportunity. https://legalcouncil.org/
