People with Serious Health Conditions Will Lose Medicaid Under Trump Administration Work Requirement Rule

BOSTON — ANCOR, the National Health Law Program (NHeLP), the Center for Public Representation, and 68 additional organizations filed an amicus brief today in Massachusetts v. Oz, detailing how the Trump administration’s Medicaid work requirements rule will strip health coverage from people with serious illnesses and disabilities.

The brief supports the plaintiff states’ motion for partial summary judgment, which argues that the administration’s Interim Final Rule unlawfully narrows the exemption Congress created for people who are medically frail or have special medical needs. The rule requires medically frail people to prove that their condition “significantly impairs” their ability to work and limits their ability to establish medical frailty through self-attestation.

The brief explains that interruptions in coverage can result in missed medications, worsening illness, emergency care, hospitalization, permanent disability, and death. It describes the importance of continuous care for people with cancer, sickle cell disease, diabetes, HIV, kidney disease, seizure disorders, cystic fibrosis, muscular dystrophy, intellectual and developmental disabilities, mental illnesses, and substance use disorders.

The brief illustrates the consequences through the experiences of Medicaid enrollees across the country, including:

• An Oregon resident managing life-threatening chronic conditions while working multiple remote jobs, who fears that proving compliance will overwhelm a body already working at capacity.
• An Indiana parent concerned that her autistic adult son will lose coverage because his disability has made steady employment difficult.
• A Washington parent whose son has epilepsy that will prevent him from working.

“The new Medicaid work requirements will interrupt access to community-based services for people with disabilities and threaten the fragile network of community providers,” said Barbara Merrill, chief executive officer for ANCOR. “The increased Medicaid coverage losses that will result from narrowing the medical frailty exemption will ultimately reduce access to services for people who truly need them and harm community providers who will continue to deliver support without receiving payment for their services. ANCOR is proud to join this brief highlighting the importance of continued access to Medicaid coverage for people with disabilities.”

“Stories such as these illustrate what’s at stake,” said Jane Perkins, Litigation Director at the National Health Law Program. “Congress excluded medically frail people from the work requirements. CMS has erected hurdles, however. People living with serious conditions need Medicaid coverage to ensure continuous access to the health care they need. They should not have to repeatedly prove that they are unable to meet the work requirements.”

Experts project that the rule’s restrictions on the medical frailty exemption will cause an average of 1.8 million additional people to lose Medicaid each year from 2027 through 2034. That represents roughly a 30 percent increase in anticipated coverage losses.

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