Twenty-five states sue Trump administration to block Medicaid work requirements

A coalition of twenty-five states and the District of Columbia filed a lawsuit against the Trump administration's new Medicaid work requirements, seeking to block rules that would require able-bodied enrollees to work, volunteer, or attend school at least twenty hours a week to keep their free health coverage.

The suit names CMS Administrator Dr. Mehmet Oz and HHS Secretary Robert F. Kennedy Jr. as defendants. It challenges an Interim Final Rule issued by the Centers for Medicare and Medicaid Services in early June, alleging the rule violates federal law and departs from Congress' original intent.

The plaintiff states, led by California, New York, and Pennsylvania, among others, want a temporary stay and preliminary injunction before an August 31 deadline to mail notices to Medicaid enrollees. The work requirements themselves are set to take effect in January 2027. The states argue the rules will strip coverage from millions of Americans, including people the states say should qualify for medical exemptions.

What the rule actually requires

The CMS rule, as Fox News reported, requires able-bodied Medicaid enrollees to work twenty hours a week, volunteer, or pursue education to maintain coverage. Individuals with severe medical conditions can seek an exemption, but they must now provide documentation proving they qualify.

Before the IFR, highly vulnerable Medicaid recipients were set to be automatically exempt. Agencies would have reviewed existing health records and granted exemptions without requiring additional paperwork from enrollees. The new rule changes that process.

Starting in 2028, enrollees without immediate medical records on file would be limited to a single opportunity to submit a "self-attestation" form declaring under penalty of perjury that they are too sick to work. Under previous guidance, enrollees could use self-attestation multiple times as their medical needs evolved.

The Washington Examiner reported that CMS guidance requires a recipient's condition to "significantly impair" their ability to work to qualify for a "medically frail" exemption, a stricter standard than prior draft iterations of the rule. Expansion enrollees aged nineteen to sixty-four must show they work, attend school, or perform community service at least eighty hours per month.

The states' case

The lawsuit makes two central claims. First, it alleges the IFR's narrower definition of medical frailty goes beyond the text of the GOP's budget reconciliation bill that authorized work requirements. Second, it argues the rule's documentation burdens will cause eligible people, people who are working or who do qualify for exemptions, to lose coverage anyway because of confusing paperwork, strict deadlines, or missing records.

The states cite CMS's own projections to make that second point. The agency estimated that 2.3 million enrollees will lose Medicaid coverage in the first year alone. It also projected that seven percent of enrollees who are either working or qualify for an exemption will still lose coverage due to administrative obstacles.

The lawsuit states plainly what the coalition fears. From the filing:

"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."

The plaintiff states also said the new rules would force them to abandon automated systems they have already built and invested in, replacing them with more complex and costly manual review processes.

The Trump administration has faced a string of legal challenges across policy areas, from voter verification orders to immigration enforcement. Some have gone against the administration at the trial level, while others have been reversed on appeal or upheld at the Supreme Court.

Who's suing, and what it tells you

The full list of plaintiffs reads like a roll call of blue-state attorneys general: California, Connecticut, Delaware, the District of Columbia, Hawaii, Illinois, Maine, Maryland, Massachusetts, New Jersey, New York, Oregon, Rhode Island, Vermont, and Washington. Arizona, Colorado, Michigan, Minnesota, Nevada, New Mexico, North Carolina, Pennsylvania, Virginia, Wisconsin, and Kentucky round out the coalition.

Kentucky stands out. It is the only state on the list that has voted reliably Republican in recent presidential elections. Its inclusion raises questions about the political dynamics behind the suit, and whether the state's Democratic governor or attorney general drove the decision.

Pennsylvania Governor Josh Shapiro offered the most politically charged framing. As the AP reported, Shapiro said:

"Donald Trump, Dr. Oz, and RFK Jr. are hellbent on trying to push aside people who rely on Medicaid to get the care they need."

New York Attorney General Letitia James struck a similar note, saying New Yorkers "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."

In other recent legal battles, the administration has secured major victories at the Supreme Court on immigration questions, a reminder that trial-level lawsuits do not always end where they start.

The administration's argument

Dr. Oz has been direct about the rationale behind the work requirements. His position is simple: Medicaid exists to help people who need it, and guardrails protect the program from abuse.

"If you can work, you should get up and work."

In a longer statement, Oz framed the requirements as an act of stewardship, not cruelty:

"If we put guardrails around these programs, we'll allow them to thrive. I'm here because I love Medicaid. The president has already said he loves and cherishes Medicaid and Medicare.... We cannot allow these programs to be defrauded into a turmoil that they cannot pull up from. If we love these programs, we will make the difficult decisions."

Fox News reached out to the White House and HHS for comment on the lawsuit. Neither response has been reported.

The core policy question is straightforward: Should able-bodied adults on Medicaid be required to work, study, or volunteer twenty hours a week? Polls have consistently shown broad public support for the concept of work requirements in safety-net programs. The legal fight, however, centers on whether CMS's specific implementation, particularly the tighter "medically frail" definition and the documentation burden, exceeds the authority Congress granted.

Kinda Serafi, a partner at Manatt Health, told the AP that the administration's own rulemaking may have opened the door to litigation. "By going beyond the clear language of the statute, CMS opened the door to this court challenge," Serafi said.

That observation cuts both ways. If the administration's rule does track the statute faithfully, the lawsuit will fail. If CMS overstepped, the courts will say so. That is how the system is supposed to work.

The real stakes

The CMS projection of 2.3 million people losing coverage in the first year deserves honest scrutiny from both sides. That number comes from the agency itself, not from an advocacy group or a Democratic opposition researcher. It reflects the agency's own estimate of what its rule will do.

But context matters. Medicaid enrollment surged during and after the COVID-19 pandemic, when continuous enrollment requirements prevented states from removing ineligible individuals from the rolls. Many states have spent the past two years unwinding that backlog. The question of how many current enrollees are able-bodied adults who could work but choose not to remains contested.

The seven-percent figure, people who are working or who qualify for exemptions but lose coverage anyway because of paperwork failures, is the more troubling number for the administration. If CMS's own modeling predicts that its rule will knock eligible people off the rolls, that is a design flaw the administration should address before the rule takes effect.

The states also argue they will bear real costs. Abandoning automated exemption systems and building manual review processes takes time and money, money that comes from state budgets and, ultimately, from taxpayers. Whether the federal government can impose those costs without adequate notice and process is a legitimate legal question.

In recent months, appellate courts have reversed lower-court rulings that blocked Trump administration policies, suggesting that early legal setbacks do not always predict final outcomes.

The principle is right, the execution has to be, too

Asking able-bodied adults to work, volunteer, or go to school in exchange for taxpayer-funded health coverage is not radical. It is common sense. Most Americans who pay for their own insurance through premiums, deductibles, and co-pays would consider it a reasonable expectation.

But the administration's rule has to match the law Congress wrote. If CMS defined "medically frail" more narrowly than the statute allows, or if the documentation requirements are designed in a way that the agency's own projections say will strip coverage from people who qualify, those are problems the administration can and should fix, before a judge does it for them.

The blue-state coalition filing this lawsuit has its own political incentives. Governors like Shapiro are not above using Medicaid litigation to score points against a Republican White House. That does not mean every claim in the suit is wrong.

The courts have shown they are willing to block administration actions they find legally deficient, and willing to reinstate them when the law supports the policy. This case will follow that same path.

Work requirements are sound policy. But sound policy still has to be implemented lawfully, clearly, and without tripping over its own paperwork. The administration should welcome that standard, and meet it.