People with Serious Health Conditions Will Lose Medicaid Under Trump Administration Work Requirement Rule
BOSTON, Massachusetts — The National Health Law Program (NHeLP), the Center for Public Representation, and 69 additional organizations filed an amicus brief today in Massachusetts v. Oz, detailing how the Trump administration’s Medicaid work requirements rule will strip health coverage from people with serious illnesses and disabilities.
The brief supports the plaintiff states’ motion for partial summary judgment, which argues that the administration’s Interim Final Rule unlawfully narrows the exemption Congress created for people who are medically frail or have special medical needs. The rule requires medically frail people to prove that their condition “significantly impairs” their ability to work and limits their ability to establish medical frailty through self-attestation.
The brief explains that interruptions in coverage can result in missed medications, worsening illness, emergency care, hospitalization, permanent disability, and death. It describes the importance of continuous care for people with cancer, sickle cell disease, diabetes, HIV, kidney disease, seizure disorders, cystic fibrosis, muscular dystrophy, intellectual and developmental disabilities, mental illnesses, and substance use disorders.
Stories such as these illustrate what’s at stake … People living with serious conditions need Medicaid coverage to ensure continuous access to the health care they rely on.
The brief illustrates the consequences through the experiences of Medicaid enrollees across the country, including:
- An Oregon resident managing life-threatening chronic conditions while working multiple remote jobs, who fears that proving compliance will overwhelm a body already working at capacity.
- An Indiana parent concerned that her autistic adult son will lose coverage because his disability has made steady employment difficult.
- A Washington parent whose son has epilepsy that will prevent him from working.
“Stories such as these illustrate what’s at stake,” said Jane Perkins, Litigation Director at the National Health Law Program. “Congress excluded medically frail people from the work requirements. CMS has erected hurdles, however. People living with serious conditions need Medicaid coverage to ensure continuous access to the health care they rely on. They should not have to repeatedly prove that they are unable to meet the work requirements.”
Experts project that the rule’s restrictions on the medical frailty exemption will cause an average of 1.8 million additional people to lose Medicaid each year from 2027 through 2034. That represents roughly a 30 percent increase in anticipated coverage losses.
The amicus brief is available here. The following organizations signed onto the brief.
Access Ready Inc.
AiArthritis
American Association of People with Disabilities
American Cancer Society Cancer Action Network
American Civil Liberties Union Foundation
American Diabetes Association
American Heart Association
American Lung Association
American Network of Community Options and Resources (ANCOR)
American Society of Clinical Oncology
Arthritis Foundation
Autistic Self Advocacy Network
Autistic Women & Nonbinary Network
Bazelon Center for Mental Health Law
Blood Cancer United
Center for Civil Justice
Center for Public Representation
Center For Elder Law & Justice
Colorado Center on Law and Policy
Colorado Legal Services
CommunicationFIRST
Community Legal Aid Society Inc. (Delaware)
Connecticut Health Policy Project
Cystic Fibrosis Foundation
Deaf Equality
Disability Belongs®
Disability Law Center of Utah
Disability Rights Connecticut
Disability Rights Education and Defense Fund (DREDF)
Disability Rights Iowa
Easterseals, Inc.
Epilepsy Foundation of America
Families USA
Georgetown University Center for Children and Families
Greater Hartford Legal Aid
Hawaii Disability Rights Center
Health Law Advocates, Inc.
Indiana Justice Project
Justice in Aging
Kentucky Protection & Advocacy
Legal Action Center
Legal Aid DC
The Legal Aid Society
Legal Council for Health Justice
Lupus Foundation of America
Massachusetts Law Reform Institute
Maternal and Child Health Access
Montana Legal Services Association
Muscular Dystrophy Association
NAACP
National Academy of Elder Law Attorneys (NAELA)
National Alliance on Mental Illness (NAMI)
National Bleeding Disorders Foundation
National Disability Rights Network
National Health Law Program
National Kidney Foundation
National Multiple Sclerosis Society
National Organization for Rare Disorders
National Patient Advocate Foundation
Nebraska Appleseed Center for Law in the Public Interest
New York Legal Assistance Group
Northwest Health Law Advocates
The Partnership for Inclusive Disaster Strategies
Pennsylvania Health Access Network
Pennsylvania Health Law Project
Pisgah Legal Services
Public Justice Center
Susan G. Komen Breast Cancer Foundation
TechTonic Justice
UnidosUS
William E. Morris Institute for Justice
