The City of Columbus, Medicaid enrollees and several major medical organizations have filed a federal lawsuit challenging regulations that will govern new Medicaid work requirements scheduled to take effect next year.
The lawsuit targets a June rule from the Centers for Medicare & Medicaid Services (CMS) that establishes how states must implement the requirements, including rules determining which beneficiaries can qualify for exemptions based on medical circumstances. The plaintiffs argue that the regulation goes beyond what Congress authorized and could cause eligible people to lose coverage because of documentation and verification requirements.
- Columbus and several medical organizations are challenging the federal Medicaid work requirement rule.
- The requirements are scheduled to begin Jan. 1, 2027.
- Certain adults ages 19 to 64 will generally need to document at least 80 hours per month of work, community service, education or qualifying job training to retain Medicaid coverage.
- The lawsuit focuses particularly on CMS’s definition of who qualifies as medically frail and therefore can receive an exemption.
- The plaintiffs argue that administrative requirements could cause people who remain eligible for Medicaid to lose coverage.
- The federal government has faced other legal challenges to the same rule.
Medicaid Work Requirements Begin in 2027
The new requirements stem from the One Big Beautiful Bill Act, which established nationwide work and community-engagement requirements for certain Medicaid beneficiaries.
Beginning Jan. 1, 2027, able-bodied, nonpregnant adults ages 19 through 64 who are subject to the requirements will generally need to complete at least 80 hours each month of qualifying work, community service, education or job training.
The legislation includes exemptions and other pathways for beneficiaries who meet specified conditions. CMS’s June rule provides states with additional instructions on how those requirements and exemptions are to be administered.
The implementation is expected to require states to establish systems for checking eligibility and documenting beneficiaries’ compliance.
Lawsuit Focuses on Medical-Frailty Exemption
A central issue in the lawsuit is CMS’s definition of “medically frail.”
The medical organizations and other plaintiffs argue that the federal regulation defines the exemption more narrowly than Congress intended. They contend that some people with serious or complex health conditions could be required to satisfy the work requirements even when their medical circumstances make consistent employment or compliance difficult.
The lawsuit identifies conditions including diabetes, cancer, HIV, substance use disorders and disabling mental health conditions among the types of health circumstances that could create challenges for affected beneficiaries. These are allegations made in the litigation and have not been resolved by the court.
The plaintiffs are represented by the National Health Law Program and Democracy Forward.
Medical Groups Join Columbus and Medicaid Enrollees
The organizations participating in the lawsuit include the American College of Physicians, American Academy of Pediatrics, Society for Adolescent Health and Medicine, Doctors for America, New Hampshire Medical Society and the New Hampshire chapter of the American Academy of Pediatrics.
Individual Medicaid beneficiaries are also plaintiffs.
The medical groups argue that interruptions in Medicaid coverage can affect patients’ ability to maintain continuity of care, obtain medications and attend medical appointments.
Andrew Racine, president of the American Academy of Pediatrics, said coverage disruptions can affect children as well as adults because children may lose coverage when adults in their households lose coverage. His comments were included in the coalition’s announcement of the lawsuit.
Plaintiffs Raise Concerns About Administrative Burden
The lawsuit also challenges the administrative process surrounding the new requirements.
The plaintiffs argue that beneficiaries could lose coverage not because they are actually ineligible, but because they fail to complete a required form, submit documentation or otherwise demonstrate compliance within the required timeframe.
Jennifer Cannistra, executive director of the National Health Law Program, said additional verification and documentation requirements can create opportunities for eligible individuals to lose coverage because of administrative errors or misunderstandings.
This concern has also featured in recent research examining how the requirements could affect Medicaid enrollment.
Research Highlights Potential Coverage Risks
Recent analyses have examined the number of Medicaid beneficiaries who could have difficulty meeting or documenting the new requirements.
An Urban Institute analysis published in September estimated that between 1.1 million and 2.3 million adults ages 19 to 24 could lose Medicaid coverage depending on how states implement the requirements and the extent to which states use strategies to reduce enrollment losses. The researchers noted that 88% of young adults in the study already participated in an activity that would qualify under the new rules.
Separately, Boston University researchers estimated that about 19.8% of Medicaid-eligible adults in expansion states could be at risk of failing to meet the 80-hour monthly threshold because of insufficient or inconsistent work hours. The study used employment data from 2023 through 2025.
Those studies assess potential effects rather than actual enrollment changes under the new requirements, which have not yet taken effect.
Columbus Says Local Costs Could Also Be Affected
The city of Columbus is participating in the lawsuit because the plaintiffs argue that Medicaid coverage losses could have consequences for local governments and healthcare providers.
According to the litigation, cities could face additional costs if uninsured or underinsured residents rely more heavily on public health services or emergency care.
Healthcare providers could also face additional administrative responsibilities as they help patients determine whether they qualify for exemptions or satisfy documentation requirements.
The plaintiffs are asking the federal court to invalidate the challenged portions of the rule, arguing that CMS exceeded its statutory authority and violated the Administrative Procedure Act.
Federal Government Faces Multiple Challenges
The Columbus case is not the only legal challenge to the Medicaid work requirement regulations.
In June, approximately two dozen states filed a separate lawsuit challenging CMS’s definition of medically frail individuals. That case also focuses on whether the federal regulation properly implements the statutory exemption created by Congress.
The separate lawsuits could shape how the federal government and states ultimately implement the requirements ahead of the January 2027 start date.
CMS has said it does not comment on pending litigation. When the rule was issued, CMS Administrator Mehmet Oz defended the approach and said the requirements were intended to establish safeguards around Medicaid eligibility.
States Preparing for January 2027
With the effective date approaching, states are preparing systems to verify beneficiaries’ qualifying activities, process exemptions and communicate the new requirements.
The implementation details will be important because states have some flexibility in how they administer the requirements. Recent research has found that choices around data matching, outreach and other administrative processes could affect the number of eligible beneficiaries who ultimately lose coverage.
The lawsuits could therefore affect both the legal framework and the practical implementation of the new Medicaid rules.
What Happens Next
The federal court will now consider the plaintiffs’ claims concerning CMS’s rule and the scope of the medical-frailty exemption.
The outcome could affect how states determine which Medicaid beneficiaries must satisfy the work requirements and how exemptions are documented.
Meanwhile, states continue preparing for the Jan. 1, 2027 implementation date. The litigation, along with other challenges to the regulations, adds another layer of uncertainty to the rollout of the new federal Medicaid eligibility requirements.
The Medicaid program is facing another legal challenge after the City of Columbus, several medical organizations and individual Medicaid enrollees filed a federal lawsuit against provisions governing new work and community-engagement requirements. The case challenges how the federal government has defined protections for people considered medically frail under the new Medicaid framework.
Medicaid Work Requirement Dispute
The federal Medicaid rule, issued by the Centers for Medicare & Medicaid Services (CMS) on June 1, 2026, establishes an 80-hour monthly requirement for certain adults ages 19 through 64 who are not pregnant and are not enrolled in Medicare. Qualifying activities can include employment, education, job training and community service. States generally must implement the requirement by January 1, 2027.
Medicaid Medical Frailty Exemption
A central issue in the Medicaid lawsuit is the definition of medical frailty. The plaintiffs argue that the federal rule adds conditions to the medical-frailty protection that they say are not included in the underlying law.
