25 states plus DC sue Trump admin over strict Medicaid work-requirement rule

On June 29, 2026, a coalition of 25 Democratic attorneys general plus the District of Columbia sued the Trump administration over an interim final rule published by CMS on June 3, 2026. The rule implements Medicaid work requirements enacted in the July 2025 reconciliation law but severely tightens the definition of 'medically frail' — the sole statutory exemption for individuals with serious mental illness, substance use disorder, or chronic disabilities. Instead of allowing states to use existing broad definitions, CMS now requires enrollees to meet a strict federal standard and submit burdensome documentation to prove inability to work. Those who fail risk losing coverage entirely, even if legitimately unable to comply. The lawsuit, co-led by California AG Rob Bonta, Massachusetts AG Andrea Joy Campbell, and New Jersey AG Jennifer Davenport, argues the rule violates the Medicaid Act, the Rehabilitation Act, and the Social Security Act, and that CMS unlawfully bypassed notice-and-comment rulemaking.

The Urban Institute projects that the underlying work requirements alone could cause between 3.0 and 7.0 million expansion enrollees to lose Medicaid coverage, as documented in its March 2026 report. The Robert Wood Johnson Foundation similarly projects that between 4.9 and 10.1 million people could lose coverage when combined with more frequent redeterminations. These are not just numbers — they represent low-income adults, many with chronic conditions or disabilities, who will face a cruel bureaucratic gauntlet to keep coverage. The alternative path is clear: expand Medicaid without punitive mandates, fund outreach to enroll the eligible, and treat coverage as the public-health infrastructure it is. Advocates must track this litigation closely and push Congress to repeal the work-requirement provisions entirely.