From DC: Court Ruling on Medicaid Work Requirements, Estate Recovery Advocacy, and Public Charge Updates

Federal Court Strikes Down Medical Frailty Definition for Medicaid Work Requirements 

Yesterday, a federal district court struck down part of a federal rule implementing H.R. 1 that would make it harder for people to meet the medical frailty exclusion from Medicaid work requirements. Under H.R. 1, individuals ages 19 to 64 enrolled in Medicaid expansion must demonstrate that they meet 80 hours per month of work or community engagement activities, or that they qualify for an exclusion.

In Massachusetts v. Oz, the 26 plaintiff states argued that the Trump administration’s rule unlawfully narrowed the definition of “medical frailty” under H.R. 1. The federal rule requires individuals to not only show that they have a medical condition or disability, but to also demonstrate that such condition would substantially impair their ability to meet the community engagement requirements. 

The federal court’s decision vacated the rule’s narrow definition of medical frailty and blocked enforcement of the medical frailty provision against the 26 plaintiff states. The court also blocked the Trump administration from penalizing those states for six months for noncompliance with the rule.

In another case, Taylor v. Kennedy, Medicaid enrollees and providers are also challenging the medical frailty definition. Justice in Aging joined an amicus brief, along with 31 other organizations, supporting the plaintiffs. The amicus brief argues that the medical frailty definition creates an onerous process that will lead to people with chronic conditions losing their Medicaid coverage. That litigation is ongoing.

For more on Medicaid work requirements and how they impact older adults, see Justice in Aging’s FAQ on this topic.

Medicaid Estate Recovery Advocacy and Opportunity to Share Stories

Justice in Aging advocates to limit and end Medicaid estate recovery at the federal and state levels. While federal law requires states to try to collect certain Medicaid long-term care costs after a person’s death, implementation of estate recovery varies across states. 

Last week, we held a webinar, Medicaid Estate Recovery: State Strategies to Mitigate Harm, outlining state policy options to limit the scope and impact of the policy on low-income families and marginalized communities. The webinar highlighted our toolkit for state advocates, advocacy messaging guide, and the Aging and Disability Health Policy Lab’s model state policies.

Media coverage of estate recovery also helps draw attention to its harmful impact and can support efforts to reform the law. The New York Times is currently looking for individuals to share first-hand experiences of how a state Medicaid agency has sought to recover payment for long-term care. The Times is also interested in stories from anyone involved in the estate recovery process, including advocates who have worked with families facing claims and people behind the collections process. Stories can be submitted online or directly to the reporter covering this issue.

Deadline Extended for Provider Sign-On Letter Opposing Public Charge

The deadline for direct service providers to sign on to the Protecting Immigrant Families (PIF) coalition letter on new public charge rules has been extended to December 11, 2026.

The Department of Homeland Security (DHS) issued new harmful public charge rules and guidance that went into effect on September 18. These changes make it harder for immigrants to access green cards and create a chilling effect on the use of public benefits as immigration rules become more confusing. A coalition of 23 states filed a lawsuit in the U.S. District Court for the Southern District of New York challenging the rule.

PIF’s national “Providers Against Public Charge” sign-on letter uplifts the voices of direct service providers who oppose harm to older immigrants and their families. It also encourages action from attorneys general representing states that did not join the public charge lawsuit.

Sign PIF’s letter by December 11, 2026.