10/30/2026
Yesterday, a U.S. District Court struck down part of the upcoming CMS work requirements provisions for Medicaid.
Specifically, the court struck the second prong of the medical frailty provision that requires a person to have a condition that “significantly impairs” their ability to comply with the work requirement. This means that people will only need to show that they fall within one of the 5 medical frailty categories outlined in the law. If you recall, the original law listed 5 categories of medical frailty that excluded individuals from the work requirement, including IDD. The IFR issued in June added a requirement that the individual have the condition and that condition significantly impair their ability to comply with the requirement. This ruling removes the second prong.
The judge also prohibits CMS from penalizing the 26 states that brought the suit for any errors or delays in implementing the work requirement for the next six months, beginning today.
For Pennsylvania, it means that the state only needs to know whether a person has one of the five conditions listed to deem a person medically frail and exclude them from the
work requirements. Pennsylvania also cannot be punished by CMS for the next six months for errors in implementation of the entire work requirement.
