Commonwealth of Massachusetts et al. v. Oz et al.

Issue: Whether CMS’ interim final rule adding an additional requirement to the medical frailty exclusion for Medicaid work requirements violates the Administrative Procedures Act? 

Background: Under legislation enacted by Congress in 2025, certain Medicaid enrollees must complete at least 80 hours per month of work, community service, or education to enroll or maintain eligibility. Congress created an exclusion for people who are “medically frail” or have special medical needs, including people with serious or complex medical conditions, certain disabilities, substance use disorders, and disabling mental health conditions.

26 states filed a lawsuit against the Centers for Medicare & Medicaid Services (CMS) Director Mehmet Oz alleging that the interim final rule implementing Medicaid work requirements violates the Administrative Procedure Act and the Spending Clause. They argue that the rule goes beyond what Congress intended, will make it harder for eligible people to maintain coverage, and will impose burdensome documentation requirements on applicants and enrollees.

Plaintiff states are asking the court to vacate and set aside the challenged provisions of the rule.

Current Status: Briefing ongoing in the District Court of Massachusetts

U.S. District Court for the District of Massachusetts Amicus Brief, Sep 10, 2026

Amici: American Public Health Association, Grantmakers in Health, Jacobs Institute of Women’s Health, National Center for Medical-Legal Partnership, Liberty Health Alliance, and 161 public health deans and scholars. 

Argument Summary: CMS went beyond Congress’s intent by requiring people with qualifying health conditions to also prove that their condition “significantly impairs” their ability to meet the 80-hour requirement, in violation of the Administrative Procedure Act. CMS ignored a wealth of evidence, showing that these work requirements will lead to significant Medicaid coverage losses and harmful health impacts for people with serious health conditions.

Outside Counsel:  Ropes & Gray LLP

Related Resources:

GW Media Relations. Public Health Leaders and 161 Scholars File Amicus Brief Challenging CMS Medicaid Work Requirement Rule. September 10, 2026. https://mediarelations.gwu.edu/public-health-leaders-and-161-scholars-file-amicus-brief-challenging-cms-medicaid-work-requirement