CHICAGO – Attorney General Kwame Raoul 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 One Big Beautiful Bill Act to be unlawful. In June 2026, Attorney General Raoul filed a lawsuit challenging 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 prove they qualify for an exemption from the work requirements.
“This decision ensures the most vulnerable Americans will not be forced to jump through bureaucratic red tape to access lifesaving medical care. This was the intent when Congress established the Medicaid program, and I am pleased to see the court agree,” Raoul said. “I will continue to advocate for all Illinoisans to have access to affordable healthcare.”
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In the decision, the District Court held that the Trump administration’s definition of “medical frailty” is contrary to law. The court vacated the unlawful 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.
Medicaid is the nation’s safety net healthcare program for low-income Americans and is jointly funded by states and the 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 prove that they qualify for an exemption from the work requirements, which increases administrative burdens, creates unnecessary red tape and puts eligible people at risk of losing their health coverage, including those who are already working. 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 in individual states 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.
Joining Raoul in filing the lawsuit were the attorneys general of Arizona, Colorado, California, Connecticut, Delaware, District of Columbia, Hawaii, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Jersey New Mexico, New York, North Carolina, Oregon, Rhode Island, Vermont, Virginia, Washington and Wisconsin. The governors of Kentucky and Pennsylvania also joined the lawsuit.
