Lawsuit from Medicaid enrollees, provider advocacy groups challenges ‘Big, Beautiful’ work requirements

Another lawsuit is challenging the Medicaid work requirements established by the 2025 One Big Beautiful Bill Act, which requires states to add additional oversight of enrollees that requires them to work a certain number of hours or be enrolled in school.

The bill contained exemptions, including for those who are deemed “medically frail.” But defining that category is the central issue of the lawsuit. Filed by five individuals who rely on Medicaid—who are suing through the National Health Law Program, a nonprofit patient advocacy firm—along with a number of provider groups, the plaintiffs argue the Centers for Medicare & Medicaid Services (CMS), in attempting to develop a framework to enforce the law, have created a process that is too burdensome and requires excessive documentation of proof.

If Medicaid enrollees who are not fit to work cannot prove their condition, they will be subject to the 80-hour monthly work requirement, or a certain number of class and volunteer hours, just like everyone else.

Plaintiffs argue that millions of otherwise eligible Americans could end up losing their only source of health insurance. They are asking a federal court to step in to halt the coming 2027 enforcement of CMS’ rules.

The guidelines were released by the agency in June, seven months before they are set to go into effect.

Joining the five Medicaid enrollees, who all state they have debilitating chronic conditions, is a prestigious lot of professional associations and nonprofits representing healthcare providers, including the American College of Physicians, American Academy of Pediatrics, Society for Adolescent Health, Doctors for America and the New Hampshire Medical Society.

One municipality is also listed as a primary plaintiff, the City of Columbus, Ohio.

Together, the lot argues in the lawsuit that federal regulations, as they stand, “improperly [restrict] the ‘medically frail’ exemption” in numerous ways, including a lack of workable definitions for the five categories of protection, which in any case would require “unduly burdensome procedures for individuals to verify” they are eligible for safety-net medical coverage.

“As a result of [the existing rule], medically frail individuals will lose health coverage to a far greater degree than anticipated by Congress. Independent experts project the statute, as enacted, would cause about 6.4 million people to lose coverage on an average annual basis between 2027 and 2034,” the court filing reads.

In a statement, the National Health Law Program put the complaint into plainer language, lamenting the disconnect between how exemptions will be enforced in relation to intent.

“Congress created the medical frailty exclusion to protect people with serious health needs, but the administration’s rule turns that protection into yet another obstacle people must overcome,” Jane Perkins, litigation director at the National Health Law Program, said. “The statute does not require medically frail people to prove that their conditions are so debilitating that they cannot meet the work requirement.”

“The statute exempts the medically frail from work requirements and does not authorize CMS to re-introduce it through the backdoor with the new rule. This rule puts access to care and, in some cases, people’s lives at risk.”

The advocacy group added that patients with serious illnesses, including diabetes, serious mental illness, cancer, and other complex medical conditions could lose access to Medicaid, which means they will be unable to get the treatment and medicine they need, ultimately making it more difficult for them to get back to work.

As it was only filed on Sept. 18, the lawsuit has yet to be argued in front of a judge. CMS and the U.S. Department of Health and Human Services (HHS), listed as defendants, have yet to formally respond.