AG Nessel Blocks Unlawful Medicaid Work Requirements for the Medically Frail

LANSING — Michigan Attorney General Dana Nessel has secured a decision by the U.S. District Court for the District of Massachusetts finding the Trump administration’s implementation of new Medicaid work requirements under the Big Beautiful Bill Act unlawful. In a lawsuit filed in June 2026, Attorney General Nessel challenged provisions of an interim final rule, which adopted a new interpretation of key terms like “medically frail,” making it harder for medically vulnerable individuals to be excused from Medicaid work requirements. The District Court held that the Trump administration’s definition of “medical frailty” is contrary to law, vacated the language, issued a permanent injunction, and granted the plaintiff states a six-month stay of enforcement to accommodate any errors or delays resulting from the necessary changes to implementation.

“The Court’s decision is a clear check on this administration, reinforcing that protections for the medically vulnerable cannot be brushed aside,” said Attorney General Nessel. “People who are seriously ill or living with disabilities should not have to fight through a maze of paperwork to keep the insurance coverage they need. My office will continue to defend the law, protect our residents, and keep eligible people from losing coverage over unnecessary red tape.”

Medicaid is the nation’s safety net healthcare program for low-income Americans and is jointly funded by the states and federal government, with the federal government providing at least 50% of the cost of services. Congress created exemptions from Medicaid’s work requirements to ensure that people with serious illnesses and disabilities do not lose coverage or face interruptions in care.

Yet despite months of working with states on implementation, earlier this year the Centers for Medicare & Medicaid Services (CMS) surprised states with an interim final rule that makes it harder for medically vulnerable individuals to be excused from the work requirements and makes other changes that increase administrative burdens, create unnecessary red tape, and put eligible people at risk of losing their health coverage — including those who are already working or qualify for an exemption. The rule disregarded substantial evidence that should have been considered, failed to adequately evaluate reasonable alternatives, and did not give states clear or workable guidance.

Past Medicaid work requirement programs have shown that added red tape causes eligible people to lose coverage, placing greater strain on state Medicaid programs, safety net providers, and emergency rooms, while increasing costs as more medically frail residents become uninsured.

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