A federal court has struck down part of the federal government’s regulations implementing new Medicaid work requirements, ruling that the Centers for Medicare & Medicaid Services (CMS) unlawfully narrowed an exemption intended to protect people with serious medical conditions and disabilities.
On October 29, 2026, the U.S. District Court for the District of Massachusetts ruled in favor of California and a multistate coalition challenging CMS’s interpretation of the medical frailty exemption under H.R. 1, the federal law establishing new Medicaid work and community engagement requirements.
Under federal law, certain individuals with serious illnesses, disabilities, substance use disorders, and other qualifying medical conditions are exempt from these requirements. However, CMS had imposed an additional condition requiring individuals to demonstrate that their medical condition significantly impaired their ability to comply with work or community engagement obligations.
The court determined that this additional restriction was inconsistent with federal law, invalidated the provision, and issued a permanent injunction preventing its enforcement.
The ruling also provides the plaintiff states with a six-month stay of enforcement concerning medical frailty determinations, allowing additional time to adjust eligibility systems and implementation procedures.
Importantly, the decision does not eliminate Medicaid work requirements or postpone their overall January 1, 2027 implementation date. The court also upheld separate federal provisions concerning the age of supporting documentation and limits on self-attestation.
What This Means for California
California’s Department of Health Care Services (DHCS) is preparing to implement new Medi-Cal work and community engagement requirements for affected adults beginning in January 2027.
The court’s decision removes an additional eligibility barrier for individuals who qualify for the medical frailty exemption. It also has implications for counties and state agencies responsible for determining eligibility, verifying exemptions, and maintaining continuity of coverage.
For Medi-Cal beneficiaries, providers, and community organizations, the ruling underscores the importance of understanding which individuals are exempt from the new requirements and how those exemptions will be administered.
While the broader federal requirements remain in place, California will need to account for the court’s decision as it continues preparing for implementation.
