Judge Blocks Medicaid Rule That Would Have Made Blind and Disabled People Prove They Can't Work

By Kaeleb Savon Heck

BOSTON, Nov. 2, 2026 — A federal judge has blocked the Trump administration from enforcing a rule that would have made it harder for blind, disabled and seriously ill people on Medicaid to qualify for an exemption from the program's new work requirements.

U.S. District Judge Richard Stearns ruled on Thursday, Oct. 29, that the Centers for Medicare & Medicaid Services (CMS) went beyond its legal authority when it added an extra test to the definition of "medically frail." Under that test, people in the groups Congress exempted would also have had to show that their condition "significantly impairs" their ability to meet the work requirement. Stearns sided with 25 states and the District of Columbia, which sued over the rule in a case known as Commonwealth of Massachusetts v. Oz.

The ruling does not cancel the work requirements. Starting Jan. 1, 2027, in most states, adults ages 19 to 64 covered through the Affordable Care Act's Medicaid expansion will need to log at least 80 hours a month of work, community service or a work program, or attend school at least half time, unless they qualify for an exemption. What the ruling changes is how hard that exemption is to get for people with serious health conditions and disabilities.

What the judge struck down

The work requirements come from the 2025 law known as the One Big Beautiful Bill Act, which President Trump signed last year. The law exempts people who are "medically frail or otherwise have special medical needs." According to MedicalDaily's summary of the law, that category covers five groups: people who are blind or disabled; people with a substance use disorder; people with a disabling mental disorder; people with a physical, intellectual or developmental disability that significantly impairs their ability to perform one or more activities of daily living; and people with serious or complex medical conditions.

In an interim final rule issued in June, CMS told states the exemption applies only if a person's "physical, mental, or other behavioral health condition significantly impairs the individual's ability to comply with the community engagement requirement," Reuters reported. Critics said that turned one hurdle into two. A person would have to fit into one of the groups Congress named, and then also prove their condition kept them from working.

Stearns agreed with the states that the second hurdle was not in the statute. MedicalDaily reported that he called the standard "beyond the powers of CMS and thus contrary to law."

"Because enforcement of an unlawful definition of 'medically frail' may lead to the disenrollment of otherwise eligible vulnerable individuals relying on Medicaid coverage for continuity of care, the States (and public) face potential for great hardship in the absence of an injunction," Stearns wrote, according to Reuters.

The judge also issued a six-month stay on federal enforcement of medical frailty determinations in the plaintiff states, MedicalDaily reported, to give those states time to revise their eligibility verification systems. That stay does not cover states that did not join the lawsuit.

What the judge left in place

The states did not win everything. Stearns upheld two other parts of the CMS rule, writing that "the government provided a non-frivolous rationale for adopting each provision," according to MedicalDaily.

• A 12-month lookback. When states use claims and encounter data to check whether someone is medically frail, they may look back only 12 months. Older diagnoses and records will not count.
• Limits on self-attestation. Starting in 2028, states may accept only one self-attestation, a person's own statement about their condition, per continuous enrollment period. During 2027, states may allow self-attestation each time frailty is checked.

Reuters noted that Stearns, an appointee of former President Bill Clinton, upheld several provisions that the Democratic-led states had also challenged. California, Massachusetts and New Jersey led the legal challenge through their attorneys general.

Why this matters for blind and disabled people

People who are blind or disabled are named directly in the law's list of medically frail groups. Under the stricter CMS test, a blind enrollee could have been asked to show not only that they are blind, but that blindness significantly impairs their ability to meet an 80-hour monthly work requirement. Under the ruling, fitting into one of the listed groups is enough on its own, at least in the plaintiff states.

That distinction matters in practice. Many blind and disabled people do work, and many want to. But meeting a strict monthly hours requirement can depend on things outside a person's control, such as accessible transportation, accessible job sites and employers willing to provide accommodations. A test that asks people to prove how much their disability limits them can push people into paperwork battles and can penalize the people who work around barriers the hardest.

Morgan Henderson, an economist who studies Medicaid at the Hilltop Institute at the University of Maryland, Baltimore County, told the Associated Press that the ruling will likely let some people get or keep coverage, describing people who would otherwise lose it because they are sick but "not quite sick enough," according to MedicalDaily.

Doctors had also objected to the extra test. "We're not trained to decide whether someone is able to work," Tucson, Arizona, physician Eva Shapiro told Medical Economics, as quoted by MedicalDaily. American Medical Association President Dr. Willie Underwood III called the decision "a victory for patients." CMS has said its rule does not make physicians responsible for deciding who must meet the requirement, a decision that falls to the states.

The scale of what is at stake

The numbers behind the fight are large. An internal analysis cited by Maryland Attorney General Anthony Brown's office in June suggested that about 150,000 adult expansion members in Maryland, or at least 45% of that group, would be disenrolled at some point under the work requirements, MedicalDaily reported. Nationally, the Congressional Budget Office projected in 2025 that work requirements in the House-passed version of the bill would increase the number of uninsured people by 4.8 million in 2034, according to a KFF analysis cited in the same report.

States still have room to set their own verification rules. Politico reported on the day of the ruling that eight states have chosen not to accept self-attestation in 2027 and will require frailty paperwork instead, according to MedicalDaily. Those states can still ask for proof of a qualifying condition, but under the ruling they cannot require proof that the condition significantly impairs a person's ability to meet the work requirement.

North Carolina, one of the states requiring documentation, welcomed the decision. Dev Sangvai, the state's health and human services secretary, said a priority is making sure people can get needed care "without facing confusing paperwork or the fear of losing coverage during treatment."

Analysis: a narrower exemption fight, not the end of it

The decision is a meaningful win for disabled and chronically ill enrollees, but it is narrow. It removes one extra hurdle in about half the country. It does not stop the work requirements, does not change the rules in states that did not sue, and leaves in place a 12-month lookback that could trip up people whose conditions are stable and well managed. A person who has been blind since birth, for example, may not have a recent medical visit about it, and could need a fresh record to show the state.

The ruling could also change. CMS declined to comment and has not said whether it will appeal, MedicalDaily reported. A separate lawsuit filed in September by physician groups, Medicaid enrollees and the City of Columbus, Ohio, which challenges the self-attestation limits, is still pending in federal court in Maryland.

What's next

• Appeal or new guidance: Watch whether CMS appeals or issues revised guidance before work requirements start on Jan. 1, 2027.
• State systems: The plaintiff states have six months under the stay to update how they verify medical frailty.
• The Maryland case: A ruling in the separate challenge to self-attestation limits could further change how people prove an exemption.
• For enrollees now: MedicalDaily advises expansion enrollees to check whether the work requirements apply to them, make sure any qualifying condition has been documented within the past 12 months, keep their address and phone number current with the state Medicaid office, and open every notice. Under federal rules, someone who gets a noncompliance notice has 30 days to show they meet the requirement or qualify for an exemption before coverage ends. Legal aid groups and community health centers can help with appeals.

Sources

• NBC News (Reuters), "Judge blocks 'medically frail' definition in Medicaid work requirement rule," Oct. 29, 2026: https://www.nbcnews.com/health/health-care/judge-blocks-medically-frail-definition-medicaid-work-requirement-rule-rcna606397
• MedicalDaily, "Judge Strikes Medicaid Test Forcing Chronically Ill Enrollees to Prove Illness Limits Work, but January Rules Stand," Oct. 31, 2026: https://www.medicaldaily.com/medicaid-medically-frail-ruling-work-requirements-480632
• AP News, "Medicaid rule forcing sick enrollees to prove frailty blocked by judge": https://apnews.com/article/trump-medicaid-chronically-ill-work-requirements-656719bd7c8358d9d5290cf54f81255b
• U.S. District Court opinion, Commonwealth of Massachusetts v. Oz, Case 1:26-cv-12962-RGS, filed Oct. 29, 2026 (via Georgetown Litigation Tracker): https://litigationtracker.law.georgetown.edu/wp-content/uploads/2026/10/Commonwealth-of-Massachusetts2026.10.29OPINION.pdf
• Bloomberg Law, "Trump Medicaid Frailty Work Limits Blocked By Federal Court": https://news.bloomberglaw.com/health-law-and-business/trump-medicaid-work-limits-on-medical-frailty-blocked-by-court