Democrats representing 25 states and the District of Columbia filed a lawsuit Monday against the Trump administration, challenging new federal guidance on Medicaid work requirements that they say will block eligible Americans from getting the healthcare they depend on.
The attorneys general and governors behind the legal action argue that an interim final rule issued earlier this month by the Centers for Medicare and Medicaid Services goes beyond what the law passed last summer actually authorizes. That legislation set the stage for significant changes to the Medicaid program.
The plaintiffs contend that the Republican administration’s narrow reading of certain parts of the law — including new restrictions on who qualifies for a medical frailty exemption — will create harmful barriers to coverage and cause confusion in states racing to update their systems before a January deadline.
“Added administrative burdens will cause individuals who are eligible for Medicaid to lose or be denied coverage,” the plaintiffs wrote in the suit. “People with disabilities, patients in the middle of cancer treatment, or those struggling with another serious or complex health condition, shouldn’t be at risk of losing the care that helps maintain their health.”
Spokespeople for the U.S. Department of Health and Human Services and CMS — the two agencies named in the lawsuit — had not responded to requests for comment at the time of this report. The Trump administration has described the new rules as practical steps to eliminate government freeloading and make sure benefits go to those who truly need them.
The Medicaid restrictions stem from Trump’s major tax and policy legislation enacted in 2025. The changes specifically affect people enrolled through the Medicaid expansion, which extended the program to more lower-income Americans in most states.
Beginning January 1st, adults between the ages of 19 and 64 who are enrolled through the expansion will be required to demonstrate they are working or performing community service for at least 80 hours per month, or attending school at least half-time. Exemptions exist for people classified as medically frail, those in addiction treatment, and certain other groups.
The CMS announcement earlier this month surprised states by introducing a new definition of medical frailty. While the law described medically frail individuals as those with substance use disorders, disabilities, or serious medical conditions, the CMS rule added a higher bar — requiring that a person’s condition “significantly impair” their ability to work, volunteer, or attend school at the levels the law demands before they can be exempted.
Under the rule, patients can self-certify that they meet this definition in 2027 and once in 2028. However, when they seek to renew coverage in 2028, they will need to provide proof. Health analysts and state Medicaid officials have said it remains unclear what existing records or documents would satisfy that requirement.
The lawsuit states that the new definition arrived “contrary to months of regular communications with CMS and preliminary guidance materials upon which Plaintiff States based their implementation plans.” The states also argue that CMS has still not given them enough information to update their systems properly.
New York Attorney General Letitia James, one of the Democrats leading the legal challenge, warned that the rule puts thousands of her state’s residents at risk of losing coverage.
“New Yorkers who are battling cancer, living with a disability, managing a serious mental health condition, or recovering from addiction should be able to get the health care they need without being buried in paperwork,” she said in a statement.
