Medicaid Work Requirements Remain on Track Despite Partial Vacatur - Morgan Lewis
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A federal court ruled that CMS's interpretation of medical-frailty exemptions from Medicaid work requirements was too narrow, finding that the agency cannot exclude disabled people from the five congressionally-defined categories based on functional limitations. The ruling affects implementation of work requirements set to take effect January 1, 2027, which could impact millions of Medicaid beneficiaries including disabled and neurodivergent individuals.
Key Points
States may have to revise beneficiary notices and eligibility systems on an accelerated timeline, keeping in mind the administrative reporting and verification burdens and potential CMS enforcement that continue to present material implementation and coverage risks. ### HISTORY OF WORK REQUIREMENTS During the first Trump administration, 13 states—Arizona, Arkansas, Georgia, Indiana, Kentucky, Main…
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