Health Groups Challenge Medicaid Work Requirement Rule in Court

Public health organizations, medical associations, and 167 health policy scholars are challenging federal Medicaid work requirement rules in Maryland, arguing that restrictions on medical exemptions could cause eligible patients with serious health conditions to lose coverage. The legal challenge targets guidance from the Centers for Medicare & Medicaid Services (CMS) implementing requirements established by Congress in 2025.

The dispute centers on provisions requiring certain Medicaid beneficiaries to complete at least 80 hours per month of work, community service, or education to qualify for or maintain coverage. Under the One Big Beautiful Bill Act of 2025, the requirements are scheduled to begin in 2027, with Congress establishing exemptions for medically frail people and individuals with special medical needs.

In Taylor v. Kennedy, the plaintiffs challenge CMS's requirement that people seeking a medical exemption demonstrate that their conditions significantly impair their ability to meet the monthly participation threshold. The challengers argue that Congress did not impose this additional standard and that the rule restricts the evidence states can accept when assessing medical frailty.

Georges C. Benjamin, CEO of the American Public Health Association, said the rule could undermine coverage protections intended for vulnerable beneficiaries.

"This damaging rule is administrative overreach that will result in the loss of health coverage for millions of Americans," said Georges C. Benjamin, CEO of the American Public Health Association.

Benjamin argued that people with chronic and complex medical conditions face disproportionate risks under the policy. He called for the administration to withdraw the rule and ensure any revised requirements follow the exemptions established by Congress.

Alison Barkoff, Hirsh Health Law and Policy Associate Professor and Program Director at the George Washington University Milken Institute School of Public Health, challenged the legal and evidentiary basis of the CMS approach.

"CMS's rule is arbitrary and capricious. It ignores – and in important respects contradicts – a wealth of evidence, including CMS's own data and research, showing that these requirements will lead to significant Medicaid coverage losses and harmful health impacts for people with serious health conditions, the very population that Congress intended to protect," said Alison Barkoff, Hirsh Health Law and Policy Associate Professor and Program Director at the George Washington University Milken Institute School of Public Health.

The challengers also argue that additional paperwork and reporting obligations could prevent eligible patients from retaining coverage. They cite previous Medicaid work requirement experiments in Arkansas and Georgia, which they say produced substantial coverage losses without measurable increases in workforce participation.

Sara Rosenbaum, Liberty Health Alliance board chair, warned that the policy could compound difficulties for healthcare providers serving communities with limited access to medical services.

"The health and health care consequences of the administration's medical frailty rule, if allowed to proceed, could not be more serious for health care providers struggling to meet the need for care in medically underserved communities nationwide," said Sara Rosenbaum, Liberty Health Alliance board chair.

The American Medical Association and eight other medical associations separately filed an amicus brief challenging the CMS guidance, according to the AMA. The association also participated in a similar legal challenge in Massachusetts, where a separate case contests the same provisions.

The AMA said the rule could increase administrative work for physicians, who may be asked to assess whether a patient's condition substantially limits participation in work or community activities. The association also warned that patients could face repeated documentation requests, with restrictions on state acceptance of self-attestation taking effect in 2028.

The AMA cited the expansion of Medicaid under the Affordable Care Act, which helped 20 million people gain coverage, and said Medicaid access is associated with earlier treatment and better health outcomes for people with serious illnesses, including cancer, heart disease, and substance use disorders.

The public health groups have asked the U.S. District Court for the District of Maryland to grant the plaintiffs' motion for summary judgment and vacate the challenged portions of the CMS rule. The organizations involved in the broader filing include the American Public Health Association, Grantmakers In Health, the George Washington University Milken Institute School of Public Health's Jacobs Institute of Women's Health and National Center for Medical-Legal Partnership, Liberty Health Alliance, and 167 public health and health policy deans, chairs, and scholars.